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Comments of Demys Limited on gTLD Draft Applicant Guidebook (geographic names)

  • To: <gtld-guide@xxxxxxxxx>
  • Subject: Comments of Demys Limited on gTLD Draft Applicant Guidebook (geographic names)
  • From: "General" <General@xxxxxxxxx>
  • Date: Sun, 14 Dec 2008 15:55:07 -0000

Dear Sirs,

We attach in .pdf format (and also for ease of reference in plain text
below) our comments regarding geographic name issues.

Given the content we shall endeavour to post this to the forum on the
full Guidebook and also to the forum for Module 2.

Thank you for your consideration.


Demys Limited
Internet Intellectual Property Management
33 Melville Street
United Kingdom

Tel:    +44 (0) 131 226 0660
Fax:    +44 (0) 131 225 6408
Web:    http://www.demys.com
This is an e-mail from an independent consulting company and may contain
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DEMYS is a UK registered trade mark, nos. 
2235341 & 2240640

Demys Limited is a company registered in Scotland under number SC197176


Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, 
CA 90292-6601

14 December, 2008

Dear Sirs


Demys Limited thanks the ICANN Board and Staff for the opportunity to
comment on the draft New gTLD Applicant Guidebook.  

The present comments relate to applications for new gTLD strings which
may correspond with or approximate to a sub-national place name listed
in the ISO 3166-2 standard.  As such, we shall endeavour to file this
posting in the comments forum relative to the Full Draft Applicant
Guidebook and separately in the forum relative to Module 2 (Evaluation

Demys requests that ICANN provide further clarification in the Guidebook
and the relative Explanatory Memorandum "Geographical Names Process" as
to the test to be applied by ICANN and/or the Geographical Names Panel
(GNP) to determine whether a string is a sub-national place name on the
basis that there appears to be some ambiguity as follows:-

First, Section of the draft Applicant Guidebook indicates that
the test is whether a string 'represents' a sub-national place name as
listed in the ISO 3166-2 standard.  The term 'represents' is not defined
in the Guidebook and clarification is sought as to whether this means an
exact match with ISO 3166-2 or something less rigid.  If the meaning is
less rigid then some further definition would be desirable.  This is
particularly important for commonly accepted abbreviations of
sub-national place names.  For example would '.lancs', a term not found
in ISO 3166-2, be held as a geographic name on the grounds that this
'represents' Lancashire, a term which is in ISO 3166-2 (under code
GB-LAN)?   If 'represents' means exact match then lancs is not a
geographic term.  However, Lancs is a commonly-accepted abbreviation for
Lancashire so that on a less rigid test it might be held to 'represent'
Lancashire.  How will this be handled in practice?

Secondly, Section of the draft Applicant Guidebook appears to
indicate at paragraph 2, first bullet point, and at paragraph 3, that
the geographic name test for all strings is one of 'meaningful
representation', whereas in Section 'meaningful
representation' is the test for ISO 3166-1 country or territory names
only and is not applied to ISO3166-2 sub-national place names.

This question is extremely important to those prospective applicants who
consider that their chosen string may be similar to a geographic term in
ISO 3166-2, particularly in light of Section paragraph 4 which
states that applications which are determined to be geographical but
without supporting documents will be considered incomplete and will not
pass Initial Evaluation.

Yours faithfully, 

Andrew DS Lothian
Chief Executive

Attachment: Demys Limited comments on the New gTLD Applicant Guidebook 14-12-2008.pdf
Description: Demys Limited comments on the New gTLD Applicant Guidebook 14-12-2008.pdf

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