Comments on the new gTLD program
Dear ICANN, Here are some general comments and concerns regarding the new gTLDs program: Rationale: ------------- - ICANN reasoning for opening new gTLDs are not convincing and not clear, particularly, with many skepticism from the Internet communities. However, we agree that there should be a plan for expansion. ICANN should not be event driven (i.e. reacting only to what is being proposed). It is not clear how frequent ICANN opens new rounds of new gTLDs, or is it only based on requests by the private sector. It is also not clear how end users' opinions are being considered. - ICANN focused on the number and size of the new domain names without regard to the interest and importance of this domain for Internet users and entire Internet and without regard to the impact of these names (socially, economically, technically, ...) on the countries and communities. The proposal lacks: + a comprehensive analysis of economic and competition impacts; + a business awareness; + an analysis of the risk of end user confusion and/or harm; New gTLDs ... Not generic any more: ------------------------------------------------ - The new gTLDs (generic TLDs) should be only for generic names and should not include names (e.g., geographic, community, language, country, brand, ...) - The introduction of new gTLDs, in categories such as: geographic names or languages, will blur the difference between ccTLDs and gTLDs and would make setting new different policies (for ccTLDs and gTLDs) more difficult. - If needed, different ??TLD programs to different categories (e.g., cityTLDs, languageTLD, communityTLD, ...) that have different and appropriate policies and procedures. - ICANN should give consideration to the specific need for non-commercial categories of TLDs including social, linguistic and cultural TLDs, and public authority sponsored TLDs, especially with respect to appropriate application procedures and financial arrangements, taking into consideration non-profit operation and developmental objectives. End users: ---------- - The need to ensure respect for national and public policy interests, in particular the need for adequate protection of geographic names and delegation/re-delegation procedures. - The need for more effective protection for intellectual property rights including local ones. - User trust and confidence on these choices. It is expected that with many gTLDs in the market users will lose their faith in the domain name system. with so many similar labels (2nd LDs) with multiple (10s or 100s) TLDs. Governments/Communities: ----------------------- - The new gTLDs program does not yet respond to all the concerns that governments have. - Stability and security of local communities that are living in harmony. Some communities (or countries) consist of multiple ethical groups with different races, religions, sectors, languages, etc, that are living somehow in harmony and peace just because of the enforcement of local laws and public policies that were developed by the communities/countries themselves. - Now, ICANN, with the new gTLD program, is involving itself in an area that is beyond its mandate. By allowing itself to set some public policies to harmonize the whole (internet) it is intervening indirectly in world cultural issues and worse, is breaching local community harmonies. If the local community/country cultural concerns are not treated sensitively, the right for a new gTLD may ignite a civil war in that local community! Local communities cannot depend on objection mechanism to avoid such a catastrophe. - The complexity and cost of the objection procedure and the implications of the proposed procedure for governments to submit objections, for example, on public order and morality grounds, should be taken into consideration. Moreover some countries are not represented in ICANN and might not learn about problematic domain names in a timely manner to be able to object.. - The new gTLD program has a very serious deficiency with respect to protection of values that are safeguarded by communities, countries, nations, and governments since ancient times. Examples of some of these values are: + Geographic names (countries, cities, provinces, ..., ) + Religion values (holy names, scripts, location, sectors, scholars, ...) + Morality and public order + Social security (ethical differences...) + Local trade names/marks - The objection process of the new gTLD program shifts the responsibilities from ICANN to the communities when it is ICANN's duty to make sure not to hurt communities by introducing a new gTLD in the domain name space that would cause havoc. The objection process involves cost and time constraints on communities and they will have to continuously monitor ICANN's processes so that an introduction of a new gTLD will not harm the community's values. - This proposed model: "if you do not like it then file an objection" cannot be used to deal with many morality and public order issues across the board. The process would put some communities on high alert and might not wait for ICANN to pass a verdict on a new gTLD - ICANN should adhere to GAC principles in general and in particular the following: + New gTLDs should respect the sensitivity regarding terms with national, cultural, geographic and religious significance. + ICANN should avoid country, territory or place names, and country, territory or regional language or people descriptions, unless in agreement with the relevant governments or public authorities. English and others: ------------------------- - The whole process (including consultations, documentations, forms, communications, people involved, ...) is done in English. Non-English speaking communities would be left behind because of the language barrier. - ICANN to be an international body, should treat all world languages equally. ICANN address languages as English and others! This can be seen in ICANN's documentations, policies, and procedures. This can be seen very clear in the new gTLD documents. For example, there is a process for English TLDs different from "other" languages TLDs, there is a need for a linguistic committee to approve IDN TLDs but it is not needed for English TLDs. - All languages must be addressed and supported equally regardless of the location of the headquarter of ICANN. The current technical limitation of the DNS system, i.e. ASCII based system, should not deter the support of the "other" languages on an equal foot. Best regards, -------------------------------- Abdulaziz H. Al-Zoman IT Consultant and Domain Name Expert ----------------------------------------------------------------------------------- Disclaimer: This message and its attachment, if any, are confidential and may contain legally privileged information. If you are not the intended recipient, please contact the sender immediately and delete this message and its attachment, if any, from your system. You should not copy this message or disclose its contents to any other person or use it for any purpose. Statements and opinions expressed in this e-mail are those of the sender, and do not necessarily reflect those of the Communications and Information Technology Commission (CITC). CITC accepts no liability for damage caused by this email.