Summary and Analysis of Comments

[Patrick Jones <patrick.jones@xxxxxxxxx>]

Summary and Analysis of Comments for:
Dot-INFO One and Two-Character Domain Names Amendment

The comment period ran from 18 February to 20 March 2010. Four comments were 
received before 20 March. One additional comment was received on 22 March 2010. 
All comments can be viewed at 
http://forum.icann.org/lists/info-scsld-amendment/.

Summary:

Three of the four commenters supported the amendment for two-character dot-INFO 
domain names (Jordi, Jothan Frakes and Antony Van Couvering). Jordi and Barbara 
Madonik noted they were opposed to the proposal for one-character dot-INFO 
domain names.

Chuck Warren, Jothan Frakes and Antony Van Couvering noted that similar 
requests had been approved by ICANN for other gTLD registries, and that the 
Afilias request for proposals and other allocation mechanisms approach assures 
that the names will go to good use. All three encouraged the Board to approve 
the amendment for dot-INFO.

Analysis:

Barbara Madonik noted that "these suffix variations [one and two-character 
domains] invite even more cases of cyber squatting. The alternative might be to 
offer first right of refusal to existing domain holders so names would not be 
high jacked."

With regard to one-character dot-INFO domain names, Jordi and Barbara Madonik 
noted they were opposed. Jordi stated "I think it would be wrong to allow one 
character domain names, .info or or any other TLD. Single character domains 
confuse people and there are no meaningful words of one character. I oppose it 
because they only valid reason for .info to allow one character seems to be 
money (extra registrations) and not service to the public."

Chuck Warren, Antony Van Couvering and Jothan Frakes provided comments of 
support for the Afilias proposal and amendment.

Antony Van Couvering stated "Afilias has gone above and beyond to assure that 
one and two-character names under .info will be put to good use.  Even without 
this
commendable stipulation, there is no reason that they shouldn't be allowed to 
allocate these domain names. As the ICANN-provided explanation/background 
explains, similar requests have been approved for other registries, and there 
is no good reason to deny it here."

Jothan Frakes stated "there is no reason that .INFO should not be treated 
equally, given the method with which they intend to responsibly allocate these 
[one and two-character dot-INFO] names."

Jothan also noted three reasons to allow one and two-character dot-INFO domain 
names to be released:

 1.  Six other gTLDs have had these restrictions lifted and have since began 
allocation of the names. The TLDs are .BIZ,  .CAT, .COOP, .MOBI,. NAME, and 
.PRO.
 2.  Restriction of single character domains in gTLDs in general is a concept 
worth evolving from. The act of restricting single characters is a dated 
concept that was

put in place as a placeholder, so that these would be available to horizontally 
expand the namespace at one point and do registrations at
the third level in the gTLDs. This plan and action never practically occurred.
    3. Between the premise of the restrictions and why they were made and the 
introduction of new TLDs, the restriction on single character SLD is no longer 
practically justified.

Finally, with respect to confusability of two-character dot-INFO domain names 
and ccTLDs, Jothan stated that while "the 2 character limit seems to be in 
place for ccTLD / ISO 3166-1 list(s) this is a concept that is wise at the root 
level.  With a four character TLD [dot-INFO], there is very little if any 
likelihood that .INFO, 2
character names whois be confused with a ccTLD.  For example, it seems to me 
unlikely that ie.info would be mistaken for a .ie domain name."

Chuck Warren's comment submitted on 22 March 2010 was included in this summary. 
Chuck comment's "support the allocation of single letters. I am pleased to see 
that that the approach proposed by the registry appears, to the best of my 
knowledge, to follow the recommendations of ICANN's GNSO Reserved Names Working 
Group." [Note - for reference, see the Final Report of the GNSO Reserved Names 
Working Group, 23 May 2007: 
http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.pdf].

Chuck stated that the Afilias proposal would enable Overstock to participate in 
the proposed RFP process to obtain o.info. "Overstock has stated its support 
the allocation of single letters by the various registries, with the 
understanding that by applying for the allocation of and using a single letter 
in any gTLD registry, this cannot preclude a party from seeking to use a single 
letter associated with their trade/brand name in a different gTLD or ccTLD. In 
today's environment, companies often develop unique website or web pages for 
different parts of their business, by registering and using consistent 
identities/ or domain names in multiple gTLDs and ccTLDs. The consistency of 
identity is a primary issue to brands that have global identity, such as 
Overstock. With the understanding that co-existence of registration and use in 
more than one single letter/gTLD is allowed, as it exists today for other 
second level registrations, I support the Afilias proposal for moving ahead 
with allocation of single letters in the manner they have proposed."

ICANN has previously approved a similar requests from other gTLD registries:
Dot-NAME (2006, two-characters at the third-level only): 
http://www.icann.org/en/registries/rsep/#2006004
puntCAT (2007, limited release of UA, UB, UV.cat): 
http://www.icann.org/en/registries/rsep/#2007001
Dot-JOBS (2007, limited release of two-character names only): 
http://www.icann.org/en/registries/rsep/#2007002
Dot-Coop (2007, release of go.coop): 
http://www.icann.org/en/registries/rsep/#2007005
Dot-Coop (2008, one and two-character names): 
http://www.icann.org/en/registries/rsep/#2008005
Dot-Mobi (2008, single character names): 
http://www.icann.org/en/registries/rsep/#2008006
Dot-BIZ (2008, one and two-character names): 
http://www.icann.org/en/registries/rsep/#2008010
Dot-Mobi (2008, two-character names): 
http://www.icann.org/en/registries/rsep/#2008011
Dot-Pro (2009, one, two, remaining three-character names): 
http://www.icann.org/en/registries/rsep/#2009002
puntCAT (2009, one and two-character names): 
http://www.icann.org/en/registries/rsep/#2009009

Next Steps:

The comment summary will be provided to ICANN's Executive Team for 
consideration along with the proposed amendment to the dot-INFO Agreement. The 
amendment is expected to be considered by the ICANN at its next available Board 
meeting.

Commenters:

Chuck Warren (http://forum.icann.org/lists/info-scsld-amendment/msg00004.html)
Antony Van Couvering 
(http://forum.icann.org/lists/info-scsld-amendment/msg00003.html)
Jothan Frakes (http://forum.icann.org/lists/info-scsld-amendment/msg00002.html)
Barbara Madonik 
(http://forum.icann.org/lists/info-scsld-amendment/msg00001.html)
Jordi (http://forum.icann.org/lists/info-scsld-amendment/msg00000.html)

--
Patrick

--
Patrick L. Jones
Internet Corporation for Assigned Names & Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292
Tel: +1 310 301 3861
patrick.jones@xxxxxxxxx
patrickjones.tel