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COMMENTS FROM ICC ON GNSO'S RECOMMENDATIONS ON IGO-INGO IDENTIFIER PROTECTIONS
- To: "comments-igo-ingo-recommendations-27nov13@xxxxxxxxx" <comments-igo-ingo-recommendations-27nov13@xxxxxxxxx>
- Subject: COMMENTS FROM ICC ON GNSO'S RECOMMENDATIONS ON IGO-INGO IDENTIFIER PROTECTIONS
- From: DUQUESNE Francois <duquesne@xxxxxxxxx>
- Date: Wed, 18 Dec 2013 17:26:24 +0000
Dear Ms Wong,
On behalf of Simon Jones, Director of the United Nations International
Computing Centre (ICC), please take note of the following comments.
ICC would like to echo the comments posted by the United Nations Office of
Legal Affairs on 12 December 2013 and further comments posted by INTERPOL on 17
December 2013 and OECD on 18 December 2013.
The IGO-INGO Identifier Protection recommendations adopted by the GNSO Council
on 27 November 2013 are of great concern to ICC, in particular the
recommendation to refuse protections for IGO acronyms in the Domain Name
System (DNS). Therefore, ICC wishes to add its voice to many other
inter-governmental organizations that have expressed similar concerns on this
important issue.
IGOs have indicated on many occasions that our intention is not to prevent in
absolute terms good faith use of our acronyms in the DNS by third parties.
Rather, IGOs are looking for solutions to pre-empt third-party abuse of our
acronyms to prevent user confusion and the resulting loss of confidence in both
IGOs and the DNS. ICC believes that at the second level, reasonable
co-existence principles and a simple and cost-neutral process could be devised
and the PDP could have explored such mechanisms, so a blanket refusal to
protect IGO acronyms was not warranted. In addition, we believe that IGOs
considerations have been ignored throughout this process and that there is
currently certainly no consensus on the matter.
We would like to recall one of the "core values" ICANN Board of Director's Code
of Conduct: "7. Employing open and transparent policy development mechanisms
that (i) promote well-informed decisions based on expert advice, and (ii)
ensure that those entities most affected can assist in the policy development
process."
It is important to recall that ICANN's founding documents require ICANN to
carry out its activities in conformity with relevant principles of
international law and applicable international conventions, to cooperate with
relevant IGOs and to duly take into account governments' and public
authorities' recommendations, recognizing that public authorities are
responsible for public policy.
The GAC repeatedly advised that IGOs, as entities created by governments under
public international law, are in an objectively different category to other
rights holders and that there is a prevailing global public interest to provide
special preventative protections for IGO names and acronyms at both the top and
second levels.
ICC therefore urges ICANN to adopt a policy that will protect IGOs in the same
manner afforded to the RCRC and the IOC; namely, the placement of their names
and acronyms in the Applicant Guidebook section 2.2.1.2.3, Strings; Ineligible
for Delegation; for both top level and second level domain names. Surely, IGOs
deserves to be treated at least on a par with these other organizations.
Sincerely yours.
______________________________
François DUQUESNE
Acting Chief, Business Management Division
[cid:image003.png@01CEFC1E.A83929A0]<http://www.unicc.org/Pages/WelcomePage.aspx>
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