Comment on Proposed Measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes
Dear ICANN Staff, We hereby respectfully submit our comments on the proposed measures to avoid public confusion with corresponding country codes. We are still unable to agree to the release of the two-character label "sg" at the second-level under gTLDs due to the following concerns. We do not agree with the Exclusive Availability Pre-Registration Period as a measure to prevent confusion and possible misuse of names. It would be a resource-intensive approach and create unnecessary burden on governments. The proposed measure is also silent on whether names would be made available to governments at a fee or no charge. If governments have to pay fees for the protection of their names, such use of public monies would not be justified. Also, brand TLDs are exempted from the implementation of this proposed measure which means that country-codes would be automatically released in such TLDs. We would still want to be able to retain the first-right of refusal in such TLDs. We do not have any objections to allow the use of our country-code in new gTLDs at the second-level, so long as there is effective recourse in incidents of abuse. However, the proposed measures do not seem to address our concerns. The Post-Registration Complaint Investigation measure calls for Registry Operators to take steps according to the requirements for handling reports pertaining to illegal conduct, which is set forth in Section 2.8 of the Registry Agreement. However, Section 2.8 relates specifically to the "protection of legal rights of third parties". We are unable to see how it could be utilised for our purposes if we wish to lodge a complaint against any inappropriate content or manner of use of the domain name which may not be illegal, but unacceptable according to our country's standards, culture and norms. This measure is also inadequate in that it only requires the RO to investigate and respond to complaints. The sole discretion to investigate and respond lies with Registry Operators. We propose that ICANN or an independent party such as an arbitration/mediation panel look into such case if all means to resolve the complaints with Registry Operators have been exhausted. Lastly, we wish to also reiterate that ICANN must be committed to step in and take actions against a Registry Operator if the Registry Operator fails to work with or comply with a governments' requests. While a government would take appropriate measures to engage with a Registry Operator on the resolution of situations involving inappropriate use of domain names, in the event that the RO does not or refuses to work with the government, ICANN must be committed to step in to remedy the situation (e.g. by revoking/deleting/removing the name.) Best Regards, Ser Pheng QUEH (Mr) Deputy Director, Internet Resource Management Policy and Competition Development Group Infocomm Development Authority of Singapore (IDA) D: (+65) 6211 0173 | F: (+65) 6659 2532 | E: serpheng@xxxxxxxx<mailto:serpheng@xxxxxxxx> | W: www.sgnic.sg<http://www.sgnic.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.