Release of Country and Territory Names within the .IKANO, .SAXO, .SCOR, .SANDVIK, .WALTER, .SANDVIKCOROMANT, .VISTA, .VISTAPRINT, .BARCLAYS, .BARCLAYCARD and .HERMES TLDs

["Ser Pheng QUEH (IMDA)" <QUEH_Ser_Pheng@xxxxxxxxxxx>]

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

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