Vietnam Internet Network Information Center (VNNIC) – .VN ccTLD manager Comments on Proposed Measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes

["Ph. Quan ly tai nguyen Internet" <qltn@xxxxxxxx>]

Dear ICANN,
             Vietnam Internet Network Information Center (VNNIC) – .VN ccTLD 
manager received ICANN’s notice for releasing of the two-character ASCII Labels 
at the second-level under gTLDs by implementing proposed measures to avoid 
confusion with corresponding country codes. We hereby respectfully submit our 
comments on these proposed measures.
             We appreciate ICANN's efforts in drafting measures that New gTLD 
registries must undertake for avoiding confusion with country code when 
releasing of the two-character at the second-level under gTLDs. However, we 
don’t support the proposals because if they are adopted, all currently reserved 
two-letter second-level domains would be released for all gTLD registries. The 
measures create burdens for all countries when the governments or ccTLD 
managers have to buy every two-character SLDs that are name of the country in 
ISO 3166-1 alpha-2 if they don’t want the SLD be released to third party. 
That’s why the measures do not really protect the interests of countries in New 
gTLD Program although it’s named as mitigating confusion with country codes.
             We (.VN ccTLD manager) request ICANN to continue the reservation 
of the two character label strings specified in the ISO 3166-1 alpha-2 
standard. Any request for releasing the label “VN” as second level domain in 
gTLDs (include of New gTLDs) must go through the process of the written request 
from ICANN and gTLG’s registries and only be released with the approval letter 
from Vietnam's Government through the GAC representative. We also request that 
ICANN maintain current notifications to the Vietnam's Government and the 
Internet community for each of the releasing requests.
Best Regard./.
VNNIC