Comments on the new gTLD program

["Abdulaziz Al-Zoman" <azoman@xxxxxxxxxxx>]

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

 


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