LACTLD comments on the Initial Report of the New gTLD Subsequent Procedures Working Group

29-10-2018

On 17 December 2015, the GNSO Council initiated a Policy Development Process and chartered the New gTLD Subsequent Procedures Working Group. The overall Working Group is tasked with calling upon the community’s collective experiences from the 2012 New gTLD Program round to determine what, if any changes may need to be made to the existing Introduction of New Generic Top-Level Domains policy recommendations from August 2007 as well as the final Applicant Guidebook dated June 2012. Those policy recommendations will remain in place for subsequent rounds.

Additionally, the PDP Working Group created 5 Work Tracks that are responsible for considering the subjects within its charter.

The PDP Working Group sought community input through two community comment periods. Recently, it has produced its Initial Report, which includes material from the full Working Group and Work Tracks 1-4.

Work Track 5 was established later than the other Work Tracks and is expected to produce a separate Initial Report. Specifically, Work Track 5 seeks to review the existing policy and implementation related to the geographic names at the top level, determine if changes are needed, and recommend policy or implementation guidance, as appropriate.

The objective of the Initial Report on overarching issues & Work Tracks 1-4 is to document the Working Group's deliberations on charter matters and preliminary recommendations, potential options for recommendations, as well as specific questions for which the Working Group was seeking input. Unlike other initial reports, this one does not contain a statement of level of consensus for the recommendations presented. Due to the large number of issues and the Co-Chairs intention to keep the process open to multiple positions of support or opposition on the recommendations, the definitive positions on the issues have not yet been established.  

The recommendations and deliberations included in the Initial Report address second-level domain name reservations, and all top-level strings except those pertaining to geographic strings at the top level. Among the questions the PDP WG is seeking feedback on, there was one focused on the 2-character strings at the top level consisting of one letter and one digit. The concerned question states:

“2.7.1.e.2: If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit (or digits more generally), should the reservation of those strings be removed? Why or why not? Do you believe that any additional analysis is needed to ensure that these types of strings will not pose harm or risk to security and stability? Please explain”.

With respect to this question, LACTLD along with many of its associate members submitted its comments which stand as follow:

Firstly, LACTLD believes that the technical questions asked by the GNSO Working Group need to be addressed and answered by relevant technical bodies, such as ICANN’s Security and Stability Advisory Committee (SSAC).

Additionally, LACTLD maintains that two-character strings consisting of one letter and one digit should NOT be permitted to be registered in future gTLD applications for two specific reasons. The first reason considers that two-character top-level domains are firmly associated with country-code Top Level domains; ccTLDs are created by IANA/PTI from two character codes laid down in ISO 3166-1 –ccTLDs have an entirely different policy background to gTLDs. Therefore, it is entirely foreseeable that the ISO Maintenance Agency could, in the future, decide to issue two character country codes including digits, as the ITU has already done: see Appendix 2 to ITU Radio Regulations.

The second reason refers to the homographic issues which have not been addressed by the GNSO. Homographic issues pose a direct threat to the security and stability of the Internet’s system of unique identifiers, including ccTLDs that might be caught up in them. Some examples are:

.cl -> .c1

.co -> .c0

.do -> .d0

.is -> .1s

With sans-serif typefaces, there is considerable risk for consumer confusion and consequent security risks, including phishing attacks. Consequently, the allowance of 2-character strings at the top level consisting of one letter and one digit would introduce instability to the DNS via visual confusion of strings. The complete version of the LACTLD statement is available below.

The New gTLD Subsequent Procedures Working Group informed that after a comprehensive review of public comments received, it will deliberate further on the preliminary recommendations contained within the Initial Report.