Comments - New gTLDs Program

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

Dear ICANN,

Please find below some comments that you should seciously consider:


§         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.

§         English and others:

ICANN claims to be a international body! However, it treats the wold
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.

§         Rationale:

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

§         Consultation Period:

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

§         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

§         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:

o       Geographic names (countries, cities, provinces, …, )

o       Religion values (holy names, scripts,  location, sectors, scholars,
…)

o       Morality and public order

o       Social security (ethical differences…)

o       Local trade names/marks

§         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.

§         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.

§         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 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

§         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.



§         GAC gTLD Principles:

We strongly ask ICANN to adhere to GAC principles in general and in
particular the following:



o       New gTLDs should respect the sensitivity regarding terms with
national, cultural, geographic and religious significance.

o       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.




-- 
Al-Zoman