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Comments on the new GTLD process from the Arab team for Domain Names and Internet Issues

  • To: gtld-guide@xxxxxxxxx
  • Subject: Comments on the new GTLD process from the Arab team for Domain Names and Internet Issues
  • From: oueichek@xxxxxxxxxxx
  • Date: Mon, 15 Dec 2008 18:02:22 +0000

The Arab team for Domain Names and Internet Issues was formed by council of Arab
ministers for Telecommunications, a council of the League of Arab States.

ICANN has introduced a new guidebook to register new gTLD, including the
mechanism of submission, requirements and procedures for objection.
The most important issues are related to the registration procedure and policy
(such as objection procedure; string contention; ?) and its effect on the
values of communities and countries (i.e Geographic names; Religion values;
Morality and public order; ?), which can threaten the Harmony in those
communities and countries.
Since ICANN has decided to precede this new gLTD program, despite of the
Potential problems, so the comments should be appropriate to amend the draft
before issuing the final version, should not to be open only to the domain names
that may be a development and expansion of the Internet without any Problems for
communities or countries.
We will enumerate important comments:
1.      Consultation Period: Given time for comments is very short (45 days 
after the
date of publishing). Even with the extra delay provided the time remains short.
This "rush" is really unjustified, especially that the issue is quite sensitive
and which would have a world-wide impact.
2.      Language Barrier: The whole process (including consolations, 
documentations,
forms, communications, people involved, ?) is done in English. Non-English
specking communities would be put in behind because of language barrier.
3.      Lack of Support from ICANN: Several countries and communities around the
world will be penalized because they will need to have recourse to expensive
legal services to draft the proposal. ICANN should provide support to these
communities during the process, either through a process of pre-application
validation of the request to ensure that the content of the request conforms to
ICANN expectations or at least through providing a list of "recommended" or
accredited firms which could provide this support.
4.      Rational : The reasons  that ICANN gives  for registration  a huge 
number of
domain names by ICANN, is unconvincing according to several issues :
a.      ICANN, with the new gTLD program, has focused on number and the size of
domain names without regard to the interest and the importance of this domain
names for Internet users and to stability of entire Internet and without regard
to its impact on the rules for the countries and communities.
b.      The term "community" per-se is rather ambiguous and could be stretched 
in an
abusive manner. For example, it is not clear if the community of expatriate
people from a certain origin X in a country could claim the domain X. What would
happen if they are in conflict of another request presented officially by the
country of origin X?
c.      ICANN, with the new gTLD program, is involving itself in an area which 
is
beyond its mandate. By allowing itself to set some public policies to harmonize
the whole internet society, it is intervening by indirect way in world cultural
issues and the worst is the process of breaching local community harmonies, if
the local community/country cultural concerns are not treated sensitively; the
right for obtaining a new gTLD may ignite conflicts inside that local community!
Local communities cannot depend on the objection mechanism to avoid such
conflicts, and this threats the Stability and Security of Local Communities (or
countries); which they are Living in Harmony and peace between  multiple ethical
groups with different religions; sectors; languages; just because of the
enforcement of local laws and public policies that were developed by the
communities/countries themselves.
5.       ICANN adopted the objection which is based on the effort of 
communities,
which may cause many problems:
a.      The objection process of the new gTLD program shifts the 
responsibilities
from ICANN to the communities, while  it ICANN's duty to make sure the emptiness
of problems in communities in case introducing any new gTLD in the domain name
space.
b.       The objection process involves cost and time constraints in the 
communities
and those communities have to continuously monitor ICANN's processes, for to be
sure this new gTLD will not harm the community?s values.
c.      The proposed model: ?if you do not like it (domain name) then file an
objection, and pay associated costs?; this model cannot be used to deal with
many morality and public order issues across the board. The process would put
some communities on high alert and might not wait for ICANN to pass a verdict on
a new gTLD.
6.      The new gTLD program has very serious deficiency with respect to 
protection
of values which safeguarded by communities, countries, nations, and governments
since ancient times. some of these values are:
-       Geographic names (countries, cities, provinces, ?, ).
-       Religion values (holy names, scripts,  location, sectors, scholars, ?).
-       Morality and public order .
-       Social security (ethical differences?).
-       Local trade names/marks.
 Till now, ICANN did not specify the Domain names which consider harmful for the
social, ethics and religious values and did not specify who is responsible for
resolving these problems and which kind of party which can introduce objection
to these Domain names.
7.      The string contention process should not use the mechanism of auctions 
as the
last resort to solve the contention between the applications which are
Community-based, which leads to deprive some communities from its right.
8.      ICANN has opened the registration process for the internationalized 
domain
names  at the IDN ccTLD and  gTLD level at the same time, which can cause many
problems like:
a.        Full IDN has not been introduced (or used) by the internet 
communities.
Introducing IDN in a large scale (e.g. part of the new gTLDs) while the
technology is still immature may lead to user confusion and mistrust in the IDN
solution.
b.       Blurring between ccTLDs and gTLDs: The introduction of new gTLDs will 
blur
the difference between ccTLDs and gTLDs and would make setting new different
policies (for ccTLDs and gTLDs) more difficult.
c.      It is expectable that with many gTLDs in the market; users will lose 
their
faith in the domain names system; (many variations for a single label with
multiple (10s or 100s) TLDs).
9.      The cost of allocating new gTLD is very high, this cost includes: (gTLD
Evaluation fee (185000 $); Registry Services Review Fee(about 50000$); Dispute
Resolution Filing Fee(between 1000 to 5000 $) and other fees like objection fee)
.
10.     gTLDs in English and different language:
ICANN claims to be a international body! However, it treats the world languages
differently. This can be seen in ICANN?s documentations, policies, and
procedures. This can be seen clearly in the new gTLD documents. For example, the
English  process of TLDs is different from the ?other? languages TLDs
process, there is a need a linguistic committee to approve IDN TLDs but it is
not needed for English TLDs. Languages must be addressed and supported equally
regardless of the ICANN headquarter location. The current technical limitation
of the DNS system, i.e. ASCII based system, should not deter the support of the
?other? languages in an equally.
11.     Low participation from the countries and communities in the setting of 
the
new gLTD  guidebook and comment it,  therefore should be a longer period of time
to educate the communities about the new domains and show them how it is
important for them before opening the area to comment  the draft, and this is
the responsibility of ICANN.
12.     GAC gTLD Principles:
We strongly ask ICANN to adhere GAC principles in general, and particularly the
following:
-New gTLDs should respect the sensitivity of regarding terms national, cultural,
geographic and religious significance.
-ICANN should avoid country, territory or place names, and country, territory or
regional language or people descriptions, unless in agreement with the relevant
governments or public authorities.



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