Comments on Module 2 by Association Uninet

[Iliya Bazlyankov <iliya@xxxxxxxxx>]

Association Uninet represents three of the biggest domain registration
and web hosting companies in Bulgaria, as well as Internet providers
and IT companies.

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2.1.1.1  Some years ago, the GNSO IDN Working group agreed that only
VISUAL similarity should be concerned. Now we see that in the current
document, ICANN has mentioned other types of similarity. Adding
"phonetic or aural or sound" similarity or "meaning" similarity in the
current draft seems unfair to potential applicants, because the
working group suggested that only visual similarity could lead to
string confusion.

2.1.1.4.1 "It is the applicant's responsibility to identify which
level of government support is required"
- ICANN requrements must be clarified, because in some countries would
be hard to obtain any governmental support, it others the government
is not interested in any TLD application. We suggest that ICANN must
define what level of support they require, for example a "letter of
non-objection" would be enough.

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Kind regards,
Iliya Bazlyankov
Chairman of Association Uninet

http://www.uninet.bg
iliya@xxxxxxxxx