Reservation of numeric‐only strings

[k mahdavi <KMahdavi@xxxxxxxxxx>]

I am writing on behalf of Telnic Limited, the registry operator for the .tel 
domain name, to comment on Verisign’s request to change the terms of its 
existing Registry Agreement with ICANN to allow it to register all-numeric 
strings in the .name TLD (including combinations of numbers and hyphens).  We 
at Telnic do not object to Verisign’s request.  However, we believe that, 
should ICANN agree to this request, it should simultaneously remove the same 
restriction on .tel.

To our knowledge, .name and .tel are the only two TLDs that are prohibited from 
allowing registration of all numeric strings as domain names. For .tel this 
prohibition is contained in the .tel charter which is included as Appendix S to 
the .tel Registry Operator Agreement. 

If ICANN decides to remove this restriction from .name then this change in 
policy should apply to .tel as well.  Approving the release of this restriction 
on one TLD and leaving it in place for another provides the first with a 
substantial commercial advantage.

In order to avoid such an unjust result, we respectfully request that, if ICANN 
decides to approve VeriSign’s request to allow all-numeric strings (and strings 
with combinations of numbers and hyphens) to be registered as domain names in 
.name, it simultaneously allow Telnic to do the same in .tel.

Telnic believes it is important to avoid conflict with ENUM , so it will 
continue to forbid the registration of single digit  domain names in .tel.  
Such domain names would be necessary for creating an ENUM tree under .tel, so 
forbidding them makes a .tel-based ENUM system impossible.

If this proposal is approved, we will work with ICANN to  promptly  amend our 
existing Sponsored TLD Registry Operator Agreement to reflect these matters . 

Yours sincerely,

Khashayar Mahdavi
CEO
Telnic Ltd.