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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

Introduction of Two-Character Domain Names for .JETZT, .GLOBAL, .NEUSTAR, .KIWI, .BERLIN

Open Date

12 September 2014 23:59 UTC

Close Date

3 October 2014 23:59 UTC

Staff Report Due

24 October 2014 23:59 UTC

Comments Closed

Report of Public Comments

View Comments

Brief Overview

To obtain community input on the proposed amendments to the Registry Agreements of several registry operators. The proposed Amendments are to implement a new registry service, submitted through the Registry Services Evaluation Process (RSEP), that would permit the introduction of two-character domain names for registration in the new gTLD namespace.

Section I: Description and Explanation

Specification 5 (Schedule of Reserved Names), Section 2 of the New gTLD Registry Agreement addresses reservations of two-character labels. As provided in Specification 5:

All two-character ASCII labels shall be withheld from registration or allocated to Registry Operator at the second level within the TLD. Such labels may not be activated in the DNS, and may not be released for registration to any person or entity other than Registry Operator, provided that such two-character label strings may be released to the extent that Registry Operator reaches agreement with the related government and country-code manager of the string as specified in the ISO 3166-1 alpha-2 standard. The Registry Operator may also propose the release of these reservations based on its implementation of measures to avoid confusion with the corresponding country codes, subject to approval by ICANN.

The New gTLD registry operators listed below submitted requests to ICANN through the Registry Services Evaluation Process (RSEP) to release certain two-character labels. In total, the requests concern five New gTLDs. Implementation of the proposal would require an amendment to the Exhibit A, Approved Services of the respective Registry Agreements, which are being posted for public comment.

Proposal TLD Registry Name Documents
2014052 berlin dotBERLIN GmbH & Co. KG dotBERLIN GmbH & Co. KG Request 1 September 2014 [PDF, 17 KB]
2014051 kiwi DOT KIWI LIMITED DOT KIWI LIMITED Request 27 August 2014 [PDF, 16 KB]
2014050 global Dot Global Domain Registry Limited Dot Global Domain Registry Limited Request 22 August 2014 [PDF, 16 KB]
2014048 neustar NeuStar, Inc. NeuStar, Inc. Request 21 August 2014 [PDF, 19 KB]
2014046 jetzt New TLD Company AB New TLD Company AB Request 6 August 2014 [PDF, 14 KB]

As part of these requests, each registry operator described the two-character domain names that it would offer for registration. These RSEP requests were posted for public information on the Registry Service Evaluation Process webpage, available at https://www.icann.org/resources/pages/rsep-2014-02-19-en.

See below for a summary of each RSEP request:

  • .berlin – On 1 September 2014, ICANN posted for public information a request made by dotBERLIN GmbH & Co. KG. The proposed service requests the release of all two-character ASCII labels that do not appear on the ISO 3166-1 alpha-2 list and for which there is no corresponding government or country-code operator. The registry operator noted in its RSEP that "Given that there is no relevant government or corresponding country-code operator, there is no way for a Registry operator to obtain permission for the release of such characters. More importantly, the release of these two-character ASCII labels poses no risk of confusion with any country-code. Therefore, the restrictions placed on this set of two-character ASCII labels are unwarranted and should be lifted forthwith".

  • .kiwi – On 27 August 2014, ICANN posted for public information a request made by DOT KIWI LIMITED. The proposed service will allow for registration and use of two-character Second Level Domains (SLD) labels within .kiwi that do not appear on the ISO 3166-1 alpha-2 list, whilst continuing to reserve two-character SLD labels that correspond to the two-character country code names or related governments. The registry operator noted in its RSEP that "For the avoidance of doubt, this means that two-character ASCII labels that currently correspond to two-character country code TLDs are not included in our RSEP".

  • .global – On 22 August 2014, ICANN posted for public information a request made by Dot Global Domain Registry Ltd. The proposal requests immediate release of all two-character ASCII labels, including two character numbers and combinations of numbers and letters, that do not appear on the ISO 31661-1 alpha-2 list and for which there is no corresponding country-code operator with an amendment to .global Registry Agreement with ICANN.

  • .neustar – On 21 August 2014, ICANN posted for public information a request made by NeuStar, Inc. The proposal requests the release of all two-character ASCII labels, regardless of whether they appear on the ISO 3166-1 alpha-2 list. The registry operator noted in its RSEP that "Upon release, these labels would be subject to all registration policies established for the .Neustar TLD including, but not limited to, the .Neustar Eligibility Requirements and Acceptable Use Policy set forth at www.nic.neustar. These policies mandate that all domains within .Neustar be registered to and controlled by Neustar and its Affiliates and Trademark Licensees and feature Neustar-branded content. Given the limited registrant universe and brand-specific use plans for .Neustar, we believe that there is virtually no risk of consumer confusion with corresponding Country Code Top Level Domains (ccTLDs). Neustar currently serves as the registry provider the .biz, .tel, and .travel Top Level Domains (TLDs), for which two-character labels are currently available for registration, and will serve as the Registry Service Provider for over 300 New gTLDs. With this experience taken into account we do not envision any threats to the security, stability, or resiliency of the Domain Name System associated with the release of two-character labels within .Neustar".

  • .jetzt – On 6 August 2014, ICANN posted for public information a request made by New TLD Company AB. The proposal requests the release of only one two-character label – "go ". The registry operator noted its intent to use "go.jetzt" as a part of its marketing and branding strategy. The registry operator noted in its RSEP request that "Also please consider the below points of reason to allow us to register go.jetzt. 1. The keyword "go" isn't a country code and does not clash with any relevant government code that we are aware of, so there is no risk for confusion and it doesn't appear on ISO 3166-1 alpha-2 list. 2. Other registries have been allowed to register "go" for their own use before, for example: go.co and go.mobi. 3. If "go" would become a country code or restricted to use in the future, the .jetzt registry would release the name for that purpose."

As provided by the Registry Services Evaluation Policy, ICANN has undertaken a preliminary determination on whether the proposals might raise significant competition, security or stability issues. ICANN's preliminary review (based on the information provided) did not identify any such issues for these requests.

To note, in its 27 March 2014 Singapore Communiqué, the GAC noted that it "discussed the Brand Registry Group proposal for a streamlined process under an addendum to the Registry Agreement for the approval of country names and 2-letter and character codes at the second level." The GAC stated that it "has no major concerns about brand owners seeking approval for such names," but that the approval should be "done directly with the countries concerned rather than through a GAC-level operational process." The GAC noted that "individual GAC members could assist with proposals relevant to their particular country if requested," and the GAC suggested that "consideration be given to establishing a register of countries that do not require individual requests to be made". Subsequent to the GAC's Singapore Communiqué, on 8 August 2014, the GAC Chair submitted a letter to the ICANN Board noting that some GAC members have raised concerns regarding the RSEP requests to release two-character labels, and as a result the GAC "intends to consider the matter at its next meeting during ICANN 51." The GAC requested that the Board take this timing into account as it considers the RSEP requests, and to continue to keep the GAC appraised of similar requests.

Section II: Background

In 2006, .name requested for a limited release of reserved two-character names which ICANN staff performed an initial technical evaluation, and referred the matter to the Registry Services Technical Evaluation Panel (RSTEP) process. The RSTEP panel considered the security and stability impacts of the proposal, which focused on unexpected responses being received from the DNS for both existing and non-existing domains, as well as simply user confusion where the idea of two letter second-level domains is unfamiliar. Based on the report of the RSTEP Panel, internal experts and other public comments, there were no significant security and stability issues related to introduction of the proposal, and the board adopted a resolution on 16 January 2007 to authorize ICANN to amend the .name Registry Agreement to implement the proposed registry services.

From 2007 to 2012, ICANN processed various RSEP proposals related to the release of two-character labels for 11 TLDs (.jobs, .coop, .mobi, .biz, .pro, .cat, .info, .travel, .tel, .asia, and .org).

On 12 June 2014, a similar public comment period regarding six RSEP proposals and amendments for the introduction of two-character domain names was opened. The six RSEP proposals are for the following 148 gTLDs: .kred, .best, .ceo, .wiki, .globo, and 143 Donuts, Inc. operated TLDs (Note: Binky Lake, LLC has submitted a RSEP request on behalf of Donuts, Inc. for 143 gTLDs.). The public comment forum for these six requests can be found here: https://www.icann.org/public-comments/two-char-new-gtld-2014-06-12-en.

On 8 July 2014, a similar public comment period regarding six more RSEP proposals and amendments for the introduction of two-character domain names was opened. The six RSEP proposals are for the following twelve gTLDs: .deals, xn--fjq720a, .city, .xyz, .college, .gop, .trade, .webcam, .bid, .healthcare, .world, and .band. The public comment forum for these six requests can be found here: https://www.icann.org/public-comments/two-char-new-gtld-2014-07-08-en.

On 23 July 2014, a similar public comment period regarding seven more RSEP proposals and amendments for the introduction of two-character domain names was opened. The seven RSEP proposals are for the following thirty-four gTLDs: .luxury, .wang, xn--3bSt00M, xn--6qQ986B3xL, xn--czRu2D, xn--45Q11C, .build, .ren, .pizza, .restaurant, .gifts, .sarl, xn--55qx5d, xn--io0a7i and 20 TLDs associated with Top Level Domain Holdings Limited. The public comment forum for these seven requests can be found here: https://www.icann.org/public-comments/two-char-new-gtld-2014-07-23-en.

On 19 August 2014, a similar public comment period regarding four more RSEP proposals and amendments for the introduction of two-character domain names was opened. The four RSEP proposals are for the following four gTLDs: .sohu, .immo, .saarland and .club. The public comment forum for these four requests can be found here: https://www.icann.org/public-comments/two-char-new-gtld-2014-08-19-en.

Section III: Relevant Resources

Section IV: Additional Information

Section V: Reports