Comment on Proposed Measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes

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

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: 
queh_ser_pheng@xxxxxxxxxx<mailto:queh_ser_pheng@xxxxxxxxxx> | W: 
www.ida.gov.sg<http://www.sgnic.sg/>
10 Pasir Panjang Road, #10-01, Mapletree Business City, Singapore 117438

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