Comment on Module 2: String Similarity Review

[Vassil Petev <vpetev@xxxxxxxxxxx>]

Hello,

My name is Vassil Petev, a Bulgarian citizen, and a Unit Manager in an 
established Bulgarian IT company.

I am submitting this comment on behalf of Bulgaria, the Cyrillic speaking 
community around the world, and the company I work for.

This comment has also been submitted to the GNSO Council on July 2, 2010 to 
support GNSO Council's request that the Applicant Guidebook section on 
"Outcomes of the String Similarity Review" be amended to allow applicants to 
request an Extended Review under applicable terms similar to those provided for 
other issues such as "DNS Stability: String Review Procedure".

I do believe however that my comments are relevant to the Draft Applicant 
Guidebook v4 as well, more notably to Module 2: Evaluation Procedures, Section 
2.2.1.1: String Similarity Review.

I hereby present to you my view and understanding of the application process 
for cases where strings are "confusingly similar" to other TLDs and/or ccTLDs, 
and request that these views are taken into account, and ultimately included in 
the Draft Applicant Guidebook v4. My views and perceptions are backed up with 
two real-life examples, the first one concerning my country, Bulgaria, and the 
second one covering a case with the company I work for. The attached document 
provides insight and analyzes in detail on:


1.      The case of the Cyrillic ccTLD for Bulgaria (*.бг) and the Latin IDN 
for Brazil (*.br):

o   Putting *.бг in context, or what is ICANN staff missing in their current 
evaluation criteria for confusingly similar strings?

o   Brazil's IDN vs. Bulgaria's IDN

o   Analysis from a user point of view


2.      The case of the Cyrillic gTLD *.ком (for компания) and the Latin gTLD 
*.com (for company)

o   Putting *.ком in context, or what is ICANN staff missing in their current 
evaluation criteria for confusingly similar strings?

o   Fraud and companies operating in Cyrillic speaking countries, and providing 
*.com domain owners the right of first say to secure their domains in the 
Cyrillic version of .com


3.      Why this matters to me: The history of the Cyrillic alphabet

I will be glad to assist you if my services and knowledge are required to 
protect the rights of the people and companies that do business in 
Cyrillic-speaking countries.

Thank you for your attention to this matter.


Regards,

Vassil Petev
Unit Manger

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Attachment: Petev on Module 2 of the Draft Applicant Guidebook 2010-07-21.pdf
Description: Petev on Module 2 of the Draft Applicant Guidebook 2010-07-21.pdf