Comments on the new GTLD process from the Arab team for Domain Names and Internet Issues
The Arab team for Domain Names and Internet Issues was formed by council of Arab ministers for Telecommunications, a council of the League of Arab States. ICANN has introduced a new guidebook to register new gTLD, including the mechanism of submission, requirements and procedures for objection. The most important issues are related to the registration procedure and policy (such as objection procedure; string contention; ?) and its effect on the values of communities and countries (i.e Geographic names; Religion values; Morality and public order; ?), which can threaten the Harmony in those communities and countries. Since ICANN has decided to precede this new gLTD program, despite of the Potential problems, so the comments should be appropriate to amend the draft before issuing the final version, should not to be open only to the domain names that may be a development and expansion of the Internet without any Problems for communities or countries. We will enumerate important comments: 1. Consultation Period: Given time for comments is very short (45 days after the date of publishing). Even with the extra delay provided the time remains short. This "rush" is really unjustified, especially that the issue is quite sensitive and which would have a world-wide impact. 2. Language Barrier: The whole process (including consolations, documentations, forms, communications, people involved, ?) is done in English. Non-English specking communities would be put in behind because of language barrier. 3. Lack of Support from ICANN: Several countries and communities around the world will be penalized because they will need to have recourse to expensive legal services to draft the proposal. ICANN should provide support to these communities during the process, either through a process of pre-application validation of the request to ensure that the content of the request conforms to ICANN expectations or at least through providing a list of "recommended" or accredited firms which could provide this support. 4. Rational : The reasons that ICANN gives for registration a huge number of domain names by ICANN, is unconvincing according to several issues : a. ICANN, with the new gTLD program, has focused on number and the size of domain names without regard to the interest and the importance of this domain names for Internet users and to stability of entire Internet and without regard to its impact on the rules for the countries and communities. b. The term "community" per-se is rather ambiguous and could be stretched in an abusive manner. For example, it is not clear if the community of expatriate people from a certain origin X in a country could claim the domain X. What would happen if they are in conflict of another request presented officially by the country of origin X? c. ICANN, with the new gTLD program, is involving itself in an area which is beyond its mandate. By allowing itself to set some public policies to harmonize the whole internet society, it is intervening by indirect way in world cultural issues and the worst is the process of breaching local community harmonies, if the local community/country cultural concerns are not treated sensitively; the right for obtaining a new gTLD may ignite conflicts inside that local community! Local communities cannot depend on the objection mechanism to avoid such conflicts, and this threats the Stability and Security of Local Communities (or countries); which they are Living in Harmony and peace between multiple ethical groups with different religions; sectors; languages; just because of the enforcement of local laws and public policies that were developed by the communities/countries themselves. 5. ICANN adopted the objection which is based on the effort of communities, which may cause many problems: a. The objection process of the new gTLD program shifts the responsibilities from ICANN to the communities, while it ICANN's duty to make sure the emptiness of problems in communities in case introducing any new gTLD in the domain name space. b. The objection process involves cost and time constraints in the communities and those communities have to continuously monitor ICANN's processes, for to be sure this new gTLD will not harm the community?s values. c. The proposed model: ?if you do not like it (domain name) then file an objection, and pay associated costs?; this model 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. 6. The new gTLD program has very serious deficiency with respect to protection of values which safeguarded by communities, countries, nations, and governments since ancient times. 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. Till now, ICANN did not specify the Domain names which consider harmful for the social, ethics and religious values and did not specify who is responsible for resolving these problems and which kind of party which can introduce objection to these Domain names. 7. The string contention process should not use the mechanism of auctions as the last resort to solve the contention between the applications which are Community-based, which leads to deprive some communities from its right. 8. ICANN has opened the registration process for the internationalized domain names at the IDN ccTLD and gTLD level at the same time, which can cause many problems like: a. 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. b. 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. c. It is expectable that with many gTLDs in the market; users will lose their faith in the domain names system; (many variations for a single label with multiple (10s or 100s) TLDs). 9. The cost of allocating new gTLD is very high, this cost includes: (gTLD Evaluation fee (185000 $); Registry Services Review Fee(about 50000$); Dispute Resolution Filing Fee(between 1000 to 5000 $) and other fees like objection fee) . 10. gTLDs in English and different language: ICANN claims to be a international body! However, it treats the world languages differently. This can be seen in ICANN?s documentations, policies, and procedures. This can be seen clearly in the new gTLD documents. For example, the English process of TLDs is different from the ?other? languages TLDs process, there is a need 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 ICANN headquarter location. The current technical limitation of the DNS system, i.e. ASCII based system, should not deter the support of the ?other? languages in an equally. 11. Low participation from the countries and communities in the setting of the new gLTD guidebook and comment it, therefore should be a longer period of time to educate the communities about the new domains and show them how it is important for them before opening the area to comment the draft, and this is the responsibility of ICANN. 12. GAC gTLD Principles: We strongly ask ICANN to adhere GAC principles in general, and particularly the following: -New gTLDs should respect the sensitivity of regarding terms 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. ---------------------------------------------------------------- This message was sent using IMP, the Internet Messaging Program. ----- End forwarded message ----- ---------------------------------------------------------------- This message was sent using IMP, the Internet Messaging Program. Attachment:
comment_newgLTD.doc |