Comment on Release of Country and Territory Names for .caravan, .art and .softbank

["Ser Pheng QUEH (IDA)" <QUEH_Ser_Pheng@xxxxxxxxxx>]

Dear ICANN,


We hereby respectfully submit our comment regarding the release of country and 
territory names currently reserved under Section 4 of Specification 5 of the 
Registry Agreement. Our comment is submitted for the RSEP requests listed in 
the table below.

No.

Proposal No.

New gTLD

1

2016031

.caravan

2

2016028

.art

3

2016023

.softbank


At this stage, we are unable to agree to the release of the two-character "sg" 
label and "singapore" at the second-level under gTLDs because of the concern 
that such use would create public confusion. Until further notice, this policy 
is to be applied to all gTLDs who have requested or will be requesting for the 
release of letter-letter two-character labels at the second level or RSEP 
requests for the release of country and territory names.

To elaborate further, we are open to considering the release of "sg" and/or 
"singapore" to registry operators who have a robust framework in place to 
address concerns of government. We recognise there are legitimate and valid 
reasons for such use. However, we are of the view that it is prudent for ICANN 
to first put in place a holistic and robust framework before approvals can be 
given. More thoughts need to be given to the evaluation process and in 
particular the remedies available should a registry operator use the approved 
names in an undesirable manner. Besides possible public confusion with the 
corresponding country code and/or country/territory name, we are also concerned 
with:

(a) The possible reputational harm if ".sg." and/or ".singapore."  is 
associated with illegal or objectionable content and/or manner-of-use; and

(b) The direct harm if ".sg." and/or ".singapore."  content or manner-of-use 
targets Singapore as a nation or Singapore entities (e.g., websites could 
masquerade as Singapore Government agencies).

ICANN's current policy focuses only on the "initial release" process. There 
needs to be considerations given to "post-release" issues. As such, the ICANN 
framework should include:

(a) A recourse for the government/country code manager to issue a notice to 
object to the content and/or manner-of-use that is misleading, questionable, 
objectionable or contrary to the country's reputation and laws. There should be 
an effective and robust process acceptable by the government/country code 
manager for the registry operator to address the concern; and

(b) Provisions to require the registry operator to re-seek approval from 
government/country code manager should there be material changes in ownership 
or organisational control (for example merger with or acquisitions by another 
entity).

In addition, ICANN must be committed to take actions against the registry 
operator should they fail to comply with the framework (e.g. implement a 
process for country/territory to raise objections to ICANN and for ICANN to 
take appropriate remedial actions such as remove/delete/revoke affected names).


Yours Sincerely,
Ser Pheng QUEH (Mr)
Deputy Director, Internet Resource Management
Policy and Competition Development Group
Infocomm Development Authority of Singapore
D: (+65) 6211 0173 | F: (+65) 6659 2532 | E: 
queh_ser_pheng@ida,gov.sg<mailto:queh_ser_pheng@ida,gov.sg> | W: 
www.ida.gov.sg<http://www.ida.gov.sg>
10 Pasir Panjang Road, #10-01, Mapletree Business City, Singapore 117438

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