Verisign Comments

["Gomes, Chuck" <cgomes@xxxxxxxxxxxx>]

Below are Verisign's comments.

Chuck Gomes


Issue: Guidelines for Developing Reference Label Generation Rulesets (LGRs) for 
the Second Level



Date:  15 December 2015



Ref: 
https://www.icann.org/public-comments/comments-lgr-second-level-2015-11-05-en


Verisign appreciates the opportunity to comment on the above named issue.  We 
agree with the RySG comments that the timing of the proposal may be premature, 
that the possible impact on stakeholders has not adequately been determined, 
and that it may not be well aligned with the larger goals for the domain 
marketplace.
In addition, in furtherance of the RySG's comments that the impact of such 
guidelines to affected parties, such as the registrars and registries, needs to 
first be understood, we add the following: language changes over time (as the 
RySG comments noted), accordingly, we would expect that label generation rules 
would also change over time.  Therefore, there is real concern that domain 
names registered (and in use) could be subject to label generation rules (and 
future iterations of such rules) that would result in domain names being 
subject to deletion due to requirements that were not in place at the time of 
registration. As a registry operator with over a million IDNs at the second 
level, we do not think that it is reasonable to expect registries to market a 
product that has the risk of being deleted.