Submitted by YoungEum on Wed, 24 June 2009 - 17:13

Country and Territory Names, new gTLD Applicant Guidebook v.2

Young-eum Lee, ccNSO representative of .kr and ccNSO vice chair, but speaking in my personal capacity.

The current distinction between gTLDs and ccTLDs is a valid and an integral part of the domain name system, as evidenced by the fact that ccTLDs now have 74.1 million registrations, comprising more than 40% of the 183 million domain name registrations, according to Verisign's June 2009 Industry Brief. That the ccTLDs satiate a significant need of the global internet users is also evidenced by the fact that it is growing at a faster rate that of the gTLDs.

I am concerned, therefore, by the fact that the 200 page analysis of the public comments of the new gTLD Applicant Guidebook version 2 still recommends that the names of countries and territories be included as part of the regional names subject to new gTLD applications, against the recommendations of the ccNSO and GAC not to (quote) "allow any string that is same and meaningful representation of a country of territory name listed in the ISO 3166-1".

The public comment analysis document explains that it is trying to accommodate the GAC statement emphasizing the sovereign rights of a government to use its name, i.e., that ICANN cannot deny a government applying for a country name under the new gTLD process because of its sovereign right.

I would like to point out a significant critical flaw behind this reasoning. It completely ignores an additional, equally important view of the ccNSO and the GAC, which says (quote)"it is of utmost importance to keep the distinctions between gTLDs and ccTLDs." There is a significant difference between the purpose and operation of ccTLDs and gTLDs (whether it is profit-oriented, service to the community, whose best interest is of the utmost concern) and the addition of a "government support" requirement in the new gTLD application does not make it a ccTLD.

If ICANN is truly cognizent of its limits and is seriously trying to accommodate the "sovereign rights" of governments, perhaps it should initiate a new ccTLD application process that is not limited to IDNs rather than a new gTLD process with regard to names of countries and territories.