Business Constituency (BC) comment on proposed amendments to Registry Agreement

[Steve DelBianco <sdelbianco@xxxxxxxxxxxxx>]

The Business Constituency (BC) supports the release of all two-character ASCII 
labels that do not correspond to any label on the ISO 3166-1 alpha-2 list, and 
requests that appropriate and established safeguards are put into place to 
protect consumers when these labels are released for registration, including 
requiring a Sunrise Period for eligible applicants.

As observed by the Governmental Advisory Committee (GAC) in its Los Angeles 
Communiqué, two-character second-level domain names are in widespread use in 
legacy gTLDs and have not affected the security, stability or resiliency of the 
DNS .  Further, there are no widespread reports or complaints from governmental 
authorities that the use of two-character ASCII labels (including those that 
correspond to a ISO 3166-1 alpha-2 listing) in legacy gTLDs has resulted in 
consumer confusion with assigned or in-use ccTLDs.

Once ANY two-character label (including those on the ISO 3166-1 alpha-2 list 
which are released with the permission of governments and country-code 
managers) are released for registration, they must be subject the same Rights 
Protection Mechanisms as any other second-level registration in the TLD in 
question (including the option to block as available).  Registry Operators 
must, at a minimum, provide standard Sunrise and Trademark Claims Services to 
protect brands who may own a Trademark in a two-character label, such as an 
acronym. Such safeguards would adequately address the remaining concerns of the 
BC in this regard.

This comment was approved in accord with the BC Charter.

Steve DelBianco
Vice chair for policy coordination
ICANN Business Constituency