comment on gTLD .MEME

[Milica Vucinic <milica.vucinic@xxxxxxxxxx>]

.Me is the ccTLD extension for Montenegro.  The Government of Montenegro note 
that a loophole exists in the ICANN Applicant Guidebook that needs to be 
addressed.

Specifically, § 2.2.1.4.1 of the Applicant Guidebook (AGB) prohibits 
applications for strings that are a country or territory name if they are a 
short-form name listed in the ISO 3166-1 standard.  The AGB also prohibits 
3-letter strings that duplicate ISO 3166 Country Codes.

Montenegro, unfortunately, has been faced with filing a formal Objection 
against Charleston Road Registry, Inc.'s application for .MEME because the 
proposed string merely consists of duplicating the two letter country code for 
Montenegro.  This loophole may have been unforeseen but it is being used, 
nevertheless.  It simply does not make a modicum of sense why the Geographic 
Names Panel did not identify the .MEME application as a Geo Name during the 
Automatic/Loop Up phase of the ICANN process.  A Sword analysis between the two 
strings reveals a score of 50%.  This loophole is dangerous because it will 
lead to probable confusion among Internet users and, even more importantly, 
have a deleterious effect on the stability and security of the Internet, which 
was a major concern listed in the GNSO Final Report.

We are awaiting the decision on the .MEME objection and wish to seek a 
favorable outcome.  It is our belief, however, that the AGB must be  modified 
to close the country-code repetition loophole and restrict gTLD applicants from 
applying for strings that simply repeat already-exising country codes listed in 
the ISO 3166 AND 3166-1


Kind regards,

Milica Vucinic
Government of Montenegro