[twochar_comments] objection to the release of “tw” as SLD under all the New gTLDs numbered from R000467 to R000541

ICANN_GAC dpt_02 at motc.gov.tw
Wed Jul 22 08:06:05 UTC 2015


Dear Sir/Madam,

I’m writing hereby to submit Taiwan government’s comments on the release of the “tw” label under the New gTLDs numbered by ICANN from R000467 to R000541.

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 75 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 2 corresponding New gTLDs would bring on concerns:
1. for “.tw.bot” (R000470):possible to make confusion with “Bank of Taiwan” (short forms: bot) and Registered website(www.bot.com.tw).
2. for “.tw.bank” (R000503): possible to make confusion with Taiwan’s bank.

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

Best Regards

Chen, Chung-Shu
Taiwan Representative to 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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