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Re: Introduction of Two-Character Domain Names in the New gTLD Namespace

  • To: comments-two-char-new-gtld-12jun14@xxxxxxxxx
  • Subject: Re: Introduction of Two-Character Domain Names in the New gTLD Namespace
  • From: Dev Anand Teelucksingh <devtee@xxxxxxxxx>
  • Date: Thu, 10 Jul 2014 19:07:54 -0400

I am the At-Large representative from the Trinidad and Tobago Computer
Society, an accredited At-Large Structure from Trinidad and Tobago, in the
Latin American and Caribbean region. I am currently serving as a member of
the At-Large Advisory Committee (ALAC) and ALAC Leadership Team, but I am
making this comment purely in my own capacity.

Various registries for multiple gTLDs are applying for exceptions to
Specification 5, Section 2 of the New gTLD Registry Agreement
("Specification 5") with some registries suggesting the release of 2
character ASCII labels not on the current ISO 3166-1 alpha 2 standard would

While this seems harmless, there is a possibility of new countries and
territories being created, and then allocated a new two character ASCII
label by ISO 3166/MA (see

Any new country or territory created after 2014 would therefore not receive
the same protection as those in the 2014 ISO 3166-1 alpha 2 list and would
find that their new 2 character ASCII label is "given away", should they
wish for their 2 character ASCII label to be protected, as per
Specification 5.

Now, should the principle established by Specification 5 protecting 2
character ASCII labels even be in the New gTLD Registry Agreement? Many
would say, especially given the prevalence of two character labels in
existing TLDs like .com that this principle shouldn't be applied to new
However, this is a separate issue to the question being asked for in this
public comment.

If Specification 5 is meant to defend the principle that 2 character ASCII
labels in the ISO 3166-1 alpha 2 list should be protected in new gTLDs,
then it should be enforced to ensure future countries and territories with
new 2 character ASCII labels are protected in the same way as those
territories and countries in today's ISO 3166-1 alpha 2 list.

Therefore, the proposals by Donuts for 143 of its new gTLDS, .kred by
KredTLD Pty Ltd, .best by BestTLD Pty Ltd and .ceo by CEOTLD Pty Ltd.
should be turned down in keeping with the principle of Specification 5.

The proposal by .wiki by Top Level Design LLC which specifies that the two
character ASCII labels will only be used for languages identified by ISO
639-1 does appear to meet the threshold that the use will not be confused
with the corresponding country codes, as per Specification 5 and could be

Similarly, the proposal by .globo by Globo Comunicação e Participações S.A
which proposed the use of two character ASCII labels that are not letters
or by two characters where only one of the character is a letter are labels
that would not be on the ISO 3166-1 alpha 2 list and could be approved.

Kind Regards,

Dev Anand Teelucksingh

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