[twochar_comments] trust; forex; cfd; spreadbetting; markets; broker; trading

[Henri Kassen]

RESPONSE TO APPLICATIONS TO AUTHORIZE TWO-CHARACTER (LETTER-LETTER) DOMAINS AT THE SECOND LEVEL BY GAC REPRESENTATIVE OF THE REPUBLIC OF NAMIBIA: 25 MAY 2015
 
We hereby respectfully submit an objection to release of names in the subject line for its registration by the registry operators of the TLD. We further request clarification from ICANN regarding the implementation of Specification 5 of the current Registry Agreement preventing all two-character ASCII labels from registration or allocation to a registry operator at the second level within the TLD. However, such two-character label strings may be released to the extent that the registry operator reaches agreement with the relevant government and country code manager of the string as specified in the ISO 3166-1 alpha-2 standard (my emphasis added). 
"na" is the country code for Namibia and the Applicants are new gTLDs. Save for an agreement between the involved Registry Operators and the Namibian Government, through facilitation by the designated government representative accredited to the GAC, the names in the subject line must remain reserved until assigned to a person or entity proposed, supported or accepted by the Namibian Government and the ccTLD manager for “na”.
The objection and request for clarification are necessitated based on the following considerations:
A national policy on the matter is due to be revised to address changes and advances in the Namibian DNS arrangements, which may require such reservations.
The Namibian Government enacted national legislation on the operation and management of the “na’ name and these are subject to revision, including ongoing consultations to develop a Namibian solution for the mandate to administer the “na” name.
The Namibian Government and wider internet community have limited understanding and appreciation for the two-character ASCII labels authorization process and need urgent and effective capacity building in this critical area from ICANN.
This would allow us to avoid third parties using the name “na” for the wrong reasons and in a way that could negatively affect the Namibian internet community and the Government of Namibia.
We shall appreciate being informed of the decision taken in regards to our request and objection.
 
Kind regards,
 
Henri Jacob Kassen
Director for ICT Development
Ministry of ICT, Government of Namibia