Release of Country and Territory Names within the .IKANO, .SAXO, .SCOR, .SANDVIK, .WALTER, .SANDVIKCOROMANT, .VISTA, .VISTAPRINT, .BARCLAYS, .BARCLAYCARD and .HERMES TLDs
Dear ICANN, We hereby respectfully submit our comment regarding the release of country and territory names currently reserved under Section 4 of Specification 5 of the Registry Agreement. Our comment is submitted for the RSEP requests listed in the table below. No. Proposal No. New gTLD 1 2016039 .ikano 2 2016042 .saxo 3 2016043 .scor 4 2016044 .sandvik 5 2016045 .walter 6 2016046 .sandvikcoromant 7 2016047 .vista 8 2016048 .vistaprint 9 2016049 .barclays 10 2016050 .barclaycard 11 2016051 .hermes At this stage, we are unable to agree to the release of "singapore" at the second-level under gTLDs because of the concern that such use would create public confusion. Until further notice, this policy is to be applied to all gTLDs who have submitted RSEP requests for the release of country and territory names. To elaborate further, we are open to considering the release of "singapore" to registry operators who have a robust framework in place to address concerns of government. We recognise there are legitimate and valid reasons for such use. However, we are of the view that it is prudent for ICANN to first put in place a holistic and robust framework, much like how it was done for the release of 2-character country-codes, before approvals can be given. More thoughts need to be given to the evaluation process and in particular the remedies available should a registry operator use the approved names in an undesirable manner. Besides possible public confusion, we are also concerned with: (a) The possible reputational harm if "singapore.gTLD" is associated with illegal or objectionable content and/or manner-of-use; and (b) The direct harm if ".singapore.gTLD" content or manner-of-use targets Singapore as a nation or Singapore entities (e.g., websites could masquerade as Singapore Government agencies). The ICANN framework for the release of country and territory names should include: (a) A recourse for the government/country code manager to issue a notice to object to the content and/or manner-of-use that is misleading, questionable, objectionable or contrary to the country's reputation and laws. There should be an effective and robust process acceptable by the government/country code manager for the registry operator to address the concern; and (b) Provisions to require the registry operator to re-seek approval from government/country code manager should there be material changes in ownership or organisational control (for example merger with or acquisitions by another entity). Thank you. Regards, QUEH Ser Pheng Deputy Director, Internet Resource Management, Connectivity and Competition Development Group D (+65) 6211 0173 | E queh_ser_pheng@xxxxxxxxxxx<mailto:queh_ser_pheng@xxxxxxxxxxx> | W: www.imda.gov.sg<http://www.imda.gov.sg/> 10 Pasir Panjang Road, #10-01, Mapletree Business City, Singapore 117438 [cid:168A4D79-8FB8-4AE1-830E-6A14C0D214E5][cid:FD1BD0D7-DA8E-48EE-A07A-CC9D858EC8DA]<https://www.facebook.com/IMDAsg/>[cid:F4E3BC34-4F29-49B8-92AF-94B819B226B8]<https://twitter.com/imdasg>[cid:C974B3D0-9AE3-4418-BDEC-6A9F6305C5B1]<https://www.youtube.com/IMDAsg>[cid:C491523B-6440-4B06-B19A-6D52A5D29BDC]<https://www.imda.gov.sg/forms/subscribe>[cid:F7072DA0-AD82-4E11-AE94-D3CD94C8EF4A] NOTICE: This e-mail (including any attachments) may contain confidential or legally privileged information. Any unauthorised use, retention, reproduction or disclosure is prohibited and may attract civil and criminal penalties. If this e-mail has been sent to you in error, please delete it and notify us immediately. Please consider the environment before you print this email.