Hi Farzi,
 
Thanks so much for doing this. Clearly this is an issue directly related to free speech on the domain name line and I certainly support the NCSG submitting a public comment on this matter. I also agree with your approach to the issue,  except for one small part. You write:
 
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REGISTRATION POLICY
 
This policy requires the registry to make sure that the registrant has taken measures to ensure against misrepresenting or falsely implying that the registrant or its business is affiliated with the government.
We find this acceptable, however misrepresentation should be interpreted narrowly. But the obligation that the registrant not to falsely imply that it is affiliated with the government is a sound approach which we support. 
 
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I don't want registry's to turn into content police or judges of the intent of registrants. I recognise there is a big push in ICANN, from the IPC, the GAC and others, to turn Registries into de facto enforcement bodies. I think this is something we should resist at any and every opportunity. What are the criteria to be used concerning government affiliation? Is this something we really want Registries to decide?
 
With that small exception I fully endorse this comment. I look forward to hearing what others have to say.
 
Thanks again, Frazi, for your hard work on this.
 
Kind Regards,
 
Ed Morris 
 
 
 
From: "James Gannon" <[log in to unmask]>
Sent: Friday, August 12, 2016 11:24 PM
To: [log in to unmask]
Subject: Re: Public comments on country codes and second level top level domains
 
Excellent moment Farzi full support to get this submitted from me.
 
 
From: NCSG-Discuss <[log in to unmask]> on behalf of farzaneh badii <[log in to unmask]>
Reply-To: farzaneh badii <[log in to unmask]>
Date: Friday 12 August 2016 at 21:05
To: "[log in to unmask]" <[log in to unmask]>
Subject: Public comments on country codes and second level top level domains
 
Hi everyone 
 
I have drafted yet another late public comment. It is a rough draft but I am sending it to get enough feedback. It is a complex matter and we might not have enough time to submit to PC.
 
We only have 5 days (17 August is the deadline). 
 
So what is the public comment about? 
 
In a nutshell, at the moment if you want to register  the domain name [in.love] you have to first request the government of India for approval because their country code is ".IN". This has resulted in a bunch of "reserved" domain names. 
 
In this public comment, we need to say  whether we approve of the criteria that  ICANN has come up with  to avoid confusion between generic two letter domain names and corresponding country codes. 
 
I think criterion number 1 is a disaster and  it is drafted in a way that entitles all the governments and cctld operators (which are sometimes businesses) to two letter second level domain in new gtlds,  for no good  reason.  You might not agree with me or think that I have gotten something wrong. please let me know.
 
If this draft is not too bad and we get enough comments on it, we can submit it to NCSG PC. If not I will submit it myself and name whoever endorses it.
 
Here is the doc. 
 
 
Best 
 
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Farzaneh