Comments on the new gTLD program - (Text mode)

["Abdulaziz Al-Zoman" <abdulaziz.alzoman@xxxxxxxxx>]

Dear ICANN,

Please find some comments on the new gTLD program

1. Language Barrier:
   The whole process (including consultations, documentations,
   forms, communications, people involved, …) is done in English.
   Non-English speaking communities would be put in behind
   because of the language barrier.


2. English and others:
   ICANN claims to be a international body! However, it treats
   the world languages differently. ICANN address languages
   as English and others! This is can bee 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.
   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 in an equal foot.

3. Rationale:
   ICANN reasoning for opening new gTLDs are not
   convincing, particularly, with many skepticism from
   the Internet communities.

4. Consultation Period:
   The consultation period of (45 days) is too short for
   a very important issue that has a world-wide impact.

5. Stability and Security of Local Communities 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

6. Protection
   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

7. Blurring between ccTLDs and gTLDs
   The introduction of new gTLDs will blur the difference between
   ccTLDs and gTLDs and would make setting new different
   policies (for ccTLDs and gTLDs) more difficult.

8. 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
   variations to maybe a single label with multiple (10s or 100s) TLDs.

9. Objection process
   The objection process of the new gTLD program shifts the
   responsibilities from ICANN to the communities. While it's
   ICANN tasks to make sure not to hurt communities by
   introducing a new gTLD in the domain name space. The
   objection process involves cost and time constraints on
   communities to continuously monitor ICANN processes so
   that no one 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 orders and would
   put communities in a high security and stability risk that
   would not wait for a ICANN mercy to acceptance the objection.

   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 i
   ntroduction 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


10. IDN gTLD
   Full IDN has not been introduced (or used) by the
   internet communities. Introducing IDN in a large
   scale (e.g. part of the new gTLDs) while the technology
   is still immature may lead to user confusion and mistrust
   in the IDN solution.

11. GAC gTLD Principles:
   We strongly ask ICANN to adhere to GAC principles in general
   and in particular the following:
   (a) New gTLDs should respect the sensitivity regarding terms
        with national, cultural, geographic and religious significance.
   (b) 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.

Best regards,

--------------------------------

Abdulaziz H. Al-Zoman
Director of SaudiNIC, CITC