I would like to second Ed's concern here. I went to the full list of gTLDs and spend some time playing around with placing two letter country codes in front of gTLDs and could hardly find anything that would look suspiciously like a government site. Misrepresentation would flow not from the two-letter/gTLD URL itself, but from the use of the domain name. Leave registries and registrar's out of enforcement there, and leave it where it belongs, with initiative taken by offended parties (including governments), or by those abused by misrepresentation.

Sam L.

On 8/13/2016 8:14 AM, Edward Morris wrote:
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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