Reservation of numeric‐only strings
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.