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Summary and Analysis of Comments

  • To: "name-numbers-and-hyphens-domains@xxxxxxxxx" <name-numbers-and-hyphens-domains@xxxxxxxxx>
  • Subject: Summary and Analysis of Comments
  • From: Francisco Arias <francisco.arias@xxxxxxxxx>
  • Date: Fri, 22 Oct 2010 13:43:00 -0700

Summary and Analysis of Comments for: Numbers & Hyphens in .NAME Domain
Names Proposed Amendment


The comment period was open from 16 September to 16 October 2010. Four
comments were received, though one of them was not relevant to the proposed
amendment. All comments can be viewed at:

Overall there was no clear consensus view; each commenter provided input
suggesting a different path.


Khashayar Mahdavi, CEO of Telnic Limited (.TEL registry) was neutral to the
proposed amendment but stated that if .NAME proposal were approved, .TEL
should also be allowed to register numeric-only domain names. Furthermore,
Mr. Mahdavi mentioned that approving the release of this restriction on one
TLD and leaving it in place for another provides the first with a
substantial commercial advantage.

Sten-Ove Tullberg supports the inclusion of hyphens while remaining neutral
to numeric-only domain names in .NAME.

Steven Metalitz opposes to the expansion of the ³Personal Name² definition
in .NAME Agreement. He wrote ³Even if there is no evidence that a person is
'commonly known by' a particular string of letters, numbers, or other
symbols, the person could plausibly assert that she use that string to
identify herself, even if only to herself or to a very limited group. This
certainly invited abuse, and also has obvious implications for the viability
of any Eligibility Requirements Dispute Resolution Policy.²

Mr. Metalitz stated ³The proposed change also has an impact on the defensive
registrations that would be available to a trademark owner, since under
[.NAME Agreement] Appendix 11 'a Defensive Registration will not be granted
if it conflicts with a then-existing Personal Name Registration.' Since a
vast new range of permissible Personal Name Registrations would be opened if
the proposed amendment were adopted, the range of potential defensive
registrations would be correspondingly diminished.²

Mr. Metalitz stated that the ICANN community and Intellectual Property right
holders in particular had relied upon the narrow scope of permissible
registrations in .NAME. He claims that the Intellectual Property
Constituency considered the current restrictions important when negotiating
with GNR, the original applicant of the .NAME proposal. He adduces that one
of the reasons why the scope of the original proposal was narrowed, was to
reduce the risk of conflict with Intellectual Property rights. Additionally,
he alleges that in 2002, the current restrictions in .NAME played a
significant role in the negotiation and ultimate approval of modifications
to the registry¹s obligations to provide public access to Whois data.

Finally, Mr. Metalitz requests that ICANN reviews and evaluates the
implications of the proposed amendment before considering it.

The fourth comment, signed by Herbert Thomas-Potts (The American Hyphen
Society) was not relevant to the proposed amendment.

Next Steps:

ICANN will consider approval of the proposed amendment to the .NAME
Agreement, taking into account the comments received.


22 September 2010
 - Herbert Thomas-Potts

1 October 2010 
 - Khashayar Mahdavi

8 October 2010 
 - Sten-Ove Tullberg

16 October 2010 
 - Steven Metalitz 

Best regards,

Francisco Arias
gTLD Registry Technical Liaison
Phone: +1 310 823 9358
PGP fingerprint: FE95 C7E7 36C7 A039 94BB  C781 FD75 BB9D C55F 51B5

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