Comments on New gTLD Draft Aplicant Guidebook

["Yu Yang" <leo@xxxxxxxxxxx>]

China Organizational Name Administration Center (CONAC) sincerely appreciates 
the endeavor and achievements made by ICANN regarding the global promotion of 
IDN. We also want to show our welcome for the publishing and public comments 
collection for the draft "New gTLD Applicant Guidebook" (the Guidebook) by 
ICANN.

Regarding Section 2.1.1.3.2 String Requirement (Module 2, page 2-7) in the 
Guidebook, which said: “Policy Requirements for Generic Top-Level Domains ?C 
Applied-for strings must be composed of three or more visually distinct letters 
or characters in the script, as appropriate”, we think this limitation should 
be discussed again. And we are willing to communicate with ICANN frankly, our 
opinions are as follows:

Chinese is composed of Chinese characters and most single Chinese characters 
are ideograms. 80% of Chinese words consist of two or even one Chinese 
character, additional Chinese characters are generally used as attribute to 
define further. Comparatively, words in letter based languages are rarely 
composed of less than 3 letters. Even abbreviations are generally composed of 3 
or more letters.

Single Chinese characters can be divided into components and radicals, but 
these smaller parts are difficult to input and are not ideograms. Therefore, 
these components and radicals should not be taken as gTLD composer as Unicode 
characters.

Most of gTLDs in operation can be explained clearly using two Chinese 
characters. According to Chinese internet users’ habit, all Chinese gTLD that 
are in the application plan of China are composed of 2 Chinese characters. If 
more characters have to be added according to the guidebook’s requirements, it 
will make the meaning unclear and give more burden to internet users for 
remembering and using these domain names.

We do understand that ICANN’s concerns about mixing short IDN gTLDs with 
current ccTLDs, but culture difference also should be respected, taking the 
interests of Chinese-speaking internet users into consideration. In that case 
IDN gTLDs could develop better.

So CONAC suggests:

1. Removing the limitation that “Applied-for strings must be composed of three 
or more visually distinct letters or characters in the script”.

2. While evaluation, analyze on a case-by-case basis regarding various 
languages.


The promotion of IDN gTLDs is a hard and great project. We know the difficulty 
of popularizing a unified policy in such a complicated language environment for 
ICANN, and we will support the work of ICANN as always.

Yang Yu

Manager, Interactive Communications

China Organizational Name Administration Center (CONAC)