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Comments on the New gTLD Applicant Guidebook Version 2 (V2), module 2

  • To: <2gtld-evaluation@xxxxxxxxx>
  • Subject: Comments on the New gTLD Applicant Guidebook Version 2 (V2), module 2
  • From: "Shahram Soboutipour" <ceo@xxxxxxxxxxx>
  • Date: Sun, 12 Apr 2009 03:29:16 +0430

Dear sirs


Please note to some my Comments on the New gTLD Applicant Guidebook Version
2 (V2), module 2:



I have been a member of GNSO IDN WG. What I remember from the sessions 2
years ago is that we agreed on limiting the similarity of TLDs to just
VISUAL similarity. This was because of the character confusions that exists
in the Unicode tables for some characters. In my language (Farsi / Persian)
such confusions are common for some characters. Also we have confusions with
Arabic characters, so the logic of that decision was decreasing the
possibility of confusion between applications provided from languages of
same root (such as Persian and Arabic) or inside one language confusions.

But now we see that ICANN has ignored all decisions made in IDN WG and added
other types of similarity.

It is a question for me that how could two TLDs from different languages
conflict with each other only in sound while they are different even in
characters or in meanings?


Item and 2

There are 2 illogical issues in these items:

1.       ICANN says there must be no conflict with the names of any cities,
county, province, or state, which is listed in lists that may change time to
time. In my country during a period of 5 years we had 4 new Provinces added.
Imagine how would be this amount for cities etc, where we have several new
cities established each year. And what is the final border of this
limitation? What I want to say is that the type ICANN has kept the field
open is very uncontrollable. There must be a restriction somewhere. Why not
asking the governments to show their red lines?

2.       As said in the item: "It is the applicant's responsibility to
identify which level of government support is required". In many countries
there are still conflicts between parallel organizations who are challenging
on the control of internet inside country (like worldwide challenges). In
such an area almost no one can succeed in getting government support. Why
should a government has such a huge control on private sectors of internet
while everybody believes that internet must not be under domination of


Item 2.2.1

How can ICANN get the diversity in new gTLD application process with such
strict laws? Many applicants are non-English ones who have not only problems
with high application fees, but also with money they have to spent for legal
translation etc for international lawyers. In such a case, it's not a
righteous act to have only one step of technical exchange.




Shahram Soboutipour

Karmania Technology Inc.

President and CEO


t/f: +98 341 2237007 | m: +98 913 1416626

e: ceo@xxxxxxxxxxx| w: www.karmania.ir



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