Comments on gTLD Application Guidebook v2

[James Seng <james@xxxxxxx>]

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With reference to Section 2.1.1.3.2, p.2-8, String Requirements,
Policy Requirements for Generic Top-Level Domains:

The policy of three or more visually distinct letter or characters is
not practical for Chinese, Japanese and Korean.

Chinese, Japanese and Korean are phonetic languages and CJK characters
are used to express the phonetics. A morpheme ("word") can be
expressed in a single or two ideographs. This is quite different from
English where a single or two characters are unlikely to have any
meaning.

It should be noted that final report of the GNSO new TLDs Committee
dated 23rd May 2007 include an sub-group report specifically on
"Single and Two Characters Labels" dated 10th May 2007 recommended
that for Single and Two Characters IDN labels

(http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm
Recommendation #5)

Single and two-character U-labels on the top level and second level of
a domain name should not be restricted in general. At the top level,
requested strings should be analyzed on a case by case basis in the
new gTLD process depending on the script and language used in order to
determine whether the string should be granted for allocation in the
DNS. Single and two character labels at the second level and the third
level if applicable should be available for registration, provided
they are consistent with the IDN Guidelines.

Recommendation:

A general principle could be based on the following principle:

If majority of the Unicode characters of the writing system for a
particular language possess a meaning on its own, then the restriction
of 3 or more character should not be applied.

Applicant should specify the classification of the writing systems of
the string they applying for, namely Logographic, Syllabic,
Alphabetic, Abugida, Abjad and Featural (See
http://en.wikipedia.org/wiki/Writing_system)

For example, a Chinese string would be Logographic. A Japanese string
consists of all hiragana or katagana would be Syallabic but would be
Logographic if it has Kanji characters.

Based on these classifications, the restriction of 3 or more character
may or may not apply.

It should also be noted that while most writing system is ambiguous
e.g. Japanese could either be Syllabic (hiragana, katagana) or
Logographic (kanji) or a combination of both, the string applied for
is more precise and well-defined.

Thus, the rule should apply on a per-string basis and not based on the
language, e.g. a Japanese hiragana string may still be restricted to 3
or more characters whereas a Japanese kanji string may be allowed on
its own.

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With reference to Section 1.1.5, p.1-11, Subsequent Application Rounds:

“ICANN’s goal is to launch subsequent gTLD application rounds as
quickly as possible.  The exact timing will be based on experiences
gained and changes required after this round is completed.  The goal
is for the next application round to begin within one year of the
close of the application submission period for this round.”

Recommendation:

Like many others, I shared the concerns that ICANN may overburden
itself by the current gTLD application.

It is uncertain how many applications ICANN would receive in this
round, 10, 100 or 1,000, and it is not clear whether ICANN has the
capacity to handle the workload. It would be advisable that ICANN be
more prudent to address and resolve existing gTLD applications before
opening up for the next round.

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With reference to various payment schedule in the draft, ICANN
recommended that payment be settled within 10 days limited.

There are countries (e.g. China) with currency control and to move
large amount of money, it would take more than 10 days to be approved
by the relevant authority.

Recommendation:

Allow partial payment within 10 days and full settlement within 30 days.