Comment on Release of Country and Territory Names within the .TORAY and .PICTET TLDs
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. 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 Devlopment Group Infocomm Development Authority of Singapore D: (+65) 6211 0173 | F: (+65) 6659 2532 | E: queh_ser_pheng@ida,gov.sg | W: www.ida.gov.sg 10 Pasir Panjang Road, #10-01, Mapletree Business City, Singapore 117438 [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/idaLogo.jpg]<http://www.ida.gov.sg/> Follow us on: [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/fb.jpg] <http://www.facebook.com/IDA.Singapore> [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/twitter.jpg] <http://twitter.com/IDAsg> [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/youtube.jpg] <http://www.youtube.com/idasingapore> [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/linkedin.jpg] <https://www.linkedin.com/company/ida-singapore> Subscribe to: [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/technews.jpg] <https://www.ida.gov.sg/Tech-Scene-News/Tech-News/Newsletter-Subscription> [https://www.ida.gov.sg/~/media/Images/Archive/templates/General/signature/bottomline.jpg] NOTICE: This e-mail (including any attachments) may contain confidential or legally privileged information. Any unauthorised use, retention, reproduction or disclosure is prohibited and may attract civil and criminal penalties. If this e-mail has been sent to you in error, please delete it and notify us immediately. Please consider the environment before you print this email.