Introduction of Two-Character Domain Names for .DEALS, XN--FJQ720A, .CITY, .XYZ, .COLLEGE, .GOP, .TRADE, .WEBCAM, .BID, .HEALTHCARE, .WORLD, .BAND

[Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>]

Dear Sir / Madam

I am submitting these comments in my capacity as founder and Managing Director 
of Blacknight, an ICANN accredited registrar based in Ireland.

While this ICANN comment period is in relation to gTLDS the underlying 
contractual obligations and related policy draw from country codes (ccTLDs). 
This is clear in the existing contract language and is also reflected in the 
comments received to date.

However I would respectfully disagree with the comments received to date.

There are no technical reasons to block two character domain names. 
While a large number of ccTLDs currently have policy restrictions with respect 
to 2 character (and 2 letter) domain names these restrictions are not 
universal. Many country codes do not impose any such restriction and, to the 
best of my knowledge, either never did or if they did they removed it at some 
point in their history.

In light of the court decision in Germany regarding vw.de the .de registry 
lifted all restrictions on two letter / character domain registrations and 
other country codes have either followed suit or are currently examining their 
existing policies.

The largest gTLD, .com, already has several domain names registered that are 
two letters and that correspond not only to country codes, but to the country 
codes of some of the larger and more important economies in the world eg. 
Uk.com, de.com and others.

There are also quite a large number of well known brands that whose trademarks 
are composed of 2 characters. A couple of examples would be 3V, VW, HP and 
there are probably thousands more. 

In light of the above I personally feel that the requests from registry 
operators to introduce two character domains should be allowed.

Regards

Michele

--
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Domains
http://www.blacknight.com/
http://blog.blacknight.com/
http://www.technology.ie
Intl. +353 (0) 59  9183072
Twitter: http://twitter.com/mneylon
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland  Company No.: 370845