[twochar_comments] [twochar comments] objection to the release of “tw” as SLD under all the New gTLDs numbered from R000375 to R000437

[ICANN_GAC]

To Whom It May Concern, 
I am writing hereby to submit Taiwan government’s comments on the release of the “tw” label under the New gTLDs numbered by ICANN from R000375 to R000437.

We object to the release of “tw” as SLD under all the above-mentioned New gTLDs for their registration by the corresponding Registry operators. We reserve the right to change position in this regard in the future.

The rationale of our objections (applied to all the foregoing 63 New gTLDs) are below:
Since “tw” label is the country code for Taiwan, the use of “tw” as SLD under these diverse New gTLDs would create confusion or concerns at multiple levels on our part, which include, but not limited to, “dwarfing national dignity”, “violation of public order or good custom”, “affecting the rights of domestic enterprises”, and “being prone to produce perplexity to our disadvantage”. For example, the uses of “tw” as SLD under the following 7 corresponding New gTLDs would bring on concerns :
1. for “.tw.adult” (reference to R000393): The “adult” belongs to sensitive string and falls within the Category 1 Safeguard Advice in GAC Beijing Communique, March 2013; the release of this domain name may affect national image from Taiwan’s perspective.
2. for “.tw.porn” (reference to R000394): The “porn” belongs to sensitive string and falls within the Category 1 Safeguard Advice in GAC Beijing Communique, March 2013; the release of this domain name may affect national image from Taiwan’s perspective.
3. for “.tw.sex” (reference to R000395): The “sex” belongs to sensitive string and falls within the Category 1 Safeguard Advice in GAC Beijing Communique, March 2013; the release of this domain name may affect national image from Taiwan’s perspective.
4. for “.tw.saarland” (reference to R000400): The “saarland” string is categorized as a Geographic TLD; the release of this domain name may bring about the degradation of statehood on Taiwan’s level.
5. for “.tw.melbourne” (reference to R000408): The “melbourne ” string is categorized as a Geographic TLD; the release of this domain name may bring about the degradation of statehood on Taiwan’s level.
6. for “.tw.sydney” (reference to R000409): The “sydney ” string is categorized as a Geographic TLD; the release of this domain name may bring about the degradation of statehood on Taiwan’s level.
7. for “.tw.dog” (reference to R000428): In Chinese, the “dog ” word possess rather negative connotation other than its denotation; the use of this domain name may be purposely linked to people’s name and hence bring about relevant abuse or defaming.

We look forward to being informed of the decisions taken in regard to our comments.

Best Regards

Chen, Chung-Shu
Taiwan Representative on the Governmental Advisory Committee of ICANN
Deputy Director
Department of Post and Telecommunications,
Ministry of Transportation and Communications
Email:dpt_02 at motc.gov.tw




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