[twochar_comments] View on the release of "hk" as the second level domain in new gTLDs posted on the ICANN website from 23 February 2015 to 19 March 2015

[hkgacrep at ogcio.gov.hk]

I am writing to express the view of Hong Kong Special Administrative 
Region Government on the release of "hk" as the second level domain (SLD) 
in new gTLDs. 

Our ccTLD, .hk, is commonly understood as the abbreviated name of Hong 
Kong.  HK means Hong Kong to the Internet community globally and locally. 
The use of "hk" as SLD in new gTLDs would give the perception that the 
domain names in question belong to or are related to Hong Kong and the 
Hong Kong community. 

(I)  gTLDs for Regulated Sectors 

As pointed out by GAC, gTLD strings that are linked to regulated or 
professional sectors should operate in a way that is consistent with 
applicable laws.  These gTLD strings or Category 1 gTLDs are likely to 
invoke a level of implied trust from consumers, and carry higher levels of 
risk associated with consumer harm.  GAC advised ICANN to apply safeguards 
(GAC Safeguard Advice 1 - 5) to these strings.  In addition, for a limited 
subset of the Category 1 gTLDs that are associated with market sectors 
which have clear and/or regulated entry requirements (i.e. 
highly-regulated sectors), additional safeguards (GAC Safeguard Advice 6 - 
8) should apply. 

In this context, for the use of "hk" as SLD in new gTLDs associated with 
(1) Highly-regulated Sectors/Closed Entry Requirements in Multiple 
Jurisdictions and (2) Inherently Governmental Functions as set out in the 
ICANN NGPC Resolution No. 2014.02.05.NG01, 

The Government of Hong Kong Special Administrative Region (HKSAR 
Government) requests that : 

(a) Registry operator should consult HKSAR Government on any request for 
domain name registration; 

(b) The registry operator should implement measures in line with GAC 
safeguards 6-8 on verification and validation of credentials of 
registrants; 

(c) Registry operator should consult HKSAR Government on any complaint 
expressing doubt with regard to authenticity of licences or credentials. 


(II)  Geographic gTLDs 

For geographic gTLDs which are names of cities, countries or regions, or 
have strong geographic connotation, putting "hk" at the second level may 
cause confusion or perception of subordination.  Among the current 
requests posted from 23 February 2015 to 19 March 2015, these gTLDs 
include: .amsterdam, .bayern, .berlin, .budapest, .capital, .city, 
.country, .frl, .hamburg, .kyoto, .london, .miami, .nagoya, .nrw, .nyc, 
.osaka, .taipei, .tirol, .tokyo, .town, .wien, .world, .yokohama, and 
.zuerich. 

In this context, HKSAR Government requests that Registry operator should 
consult HKSAR Government on any request for domain name registration on 
such gTLDs. 


Best Regards, 
Victor Lam, 
Government Chief Information Officer 
GAC Representative of Hong Kong Special Administrative Region, China 

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