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Red Tape Set to Snuff Out Online Identity of Wales

Wales, a small Celtic country that has proudly withstood the depredations of Anglo-Saxons, Normans, and tourists, which has given the world everything from an enduring mythology to the world’s longest single-world domain name, has been informed that they will not be allowed to proceed with .CYM (short for the Welsh name for Wales, Cymru) because that three-letter code is already claimed by the Cayman Islands.

Actually, that’s not quite correct. .CYM is the three-letter International Standards Organization (ISO) code for the Cayman Islands—it’s unclear if the Cayman Islands requested it or even knows very much about about it. The ISO puts out a list of three-letter country and territory codes, as well as the more two-letter codes that are used to designate country-code domain. The two-letter code for the Cayman Islands is .KY; Wales doesn’t have a two-letter country-code top-level domain, which is why they are campaigning for a new three-letter gTLD.

This is a great example of red tape getting in the way of doing the right thing. The Cayman Islands has small use (if any) of their three-letter code, and no use that couldn’t be equally well served by a different code. Three-letter codes are reserved and changed all the time—the Universal Postal Union (UPU) and the International Telecommunications Union (ITU), or the relevant sovereign power (in this case, the U.K.).

Why is this happening? It’s certainly not what’s been advertised by the leaders of the groups who could do something about it.

In his opening address at the ICANN meeting in Brussels in June 2010, CEO Rod Beckstrom called for increased international co-operation between ICANN and other global organizations.

In the address opening the Internet Governance Forum (IGF) meeting in Vilnius, Lithuania, in September 2010, Neelie Kroes, Vice-President of the European Commission responsible for Digital Agenda, in a speech entitled Moving from reflection to action on Internet governance, said “we need more concrete progress towards enhanced cooperation.”

And at the International Telecommunciations Union (ITU) plentipotentiary meeting in Guadalajara, Mexico, in October 2010, ITU Secretary-General Hamadoun Touré talked about “protect[ing] the all-important principle of multilateralism and cooperation among the international community in the modern world.”

In each case, applause from the crowd! Everyone, apparently, is for increased international co-operation—or maybe only up to the point where they actually have do something to make it happen.

Meanwhile, various anti-TLD lobbyists and ICANN’s Government Advisory Committee (GAC) have been wringing their hands about how the proposed gTLD process might be unfairly biased toward “insiders” who have spent some time decrypting ICANN’s byzantine structures and rules, at the expense of small and deserving applications—such as the application by Wales for .CYM.

It seems that everyone is of the same mind about international co-operation and making sure that deserving TLD applications get a fair shake. If so, here’s their chance to do the right thing. ICANN, the ITU, and the GAC should try some of that international co-operation and ask the ISO to change the Cayman Islands three-letter code—“CMI” is available, for example—and let Wales use .CYM, which is the natural abbreviation for the name of their country, in their language.

Let’s hope that this much-vaunted international co-operation doesn’t just mean an agreement to stand on the sidelines and use the “rules” as an excuse to do nothing. .CYM is a much stronger TLD than any alternative, and would do much for the stature of a valiant and vibrant country that has too often been given short shrift.

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UPDATE Antony Van Couvering  –  Nov 8, 2010 10:20 PM

I wanted to include this update from my blog:

“UPDATE: An astute commenter has noted that my proposal is arbitrary and unfair to the Cayman Islands, and on consideration I have to agree. The better solution would be to stop excluding new TLDs just because they happen to match an entry on the ISO 3166 three-letter list. As Jean Guillon has pointed out, at least three other known projects would be excluded: .VEN (Venice); .AND (Andalusia); and .FRA (France), although this last would be excluded for other reasons as well. Or better yet, stop using the ISO 3166 three-letter list altogether. The protections it affords to countries are debatable, and it’s certainly affecting worthy applications.”

How is this 'red tape'?The Welsh Nationalists Phillip Hallam-Baker  –  Nov 9, 2010 4:25 AM

How is this ‘red tape’?

The Welsh Nationalists made a bid, they lost to a competing bid. That may not be the outcome that you desire, but that is a different issue.

The three letter rule was adopted by Postel for purely pragmatic reasons three decades ago. The reasons are fairly obvious.

One of the reasons that Postel resisted granting the country codes in the first place was that he could see that it would lead to all manner of political complications as irredentist disputes of various flavors settled on the domain name system as a forum. The decision to use the ISO country codes was taken in order to punt that particular decision to UN which has an apparatus for handling such disputes.

ICANN would be well advised to adopt a policy of refusing all GTLD applications based on nationalist or separatist groups unless and until they obtain an ISO country code precisely to avoid involvement in such issues.

Ironically, the reason that Postel was forced to assign the country codes in the first case was that the UK JANET network already used uk.ac as its designator. Which is not a valid code, merely a reserved code. And the UK’s reason for insisting on using .uk instead of .gb has everything to do with an irredentist territorial dispute.

I understand Postel's reasons, and they were Antony Van Couvering  –  Nov 9, 2010 7:59 AM

I understand Postel’s reasons, and they were sound.  I think it makes a lot of sense when it comes to the two-letter codes.  Three-letter codes, however, aren’t used (to my knowledge at least) as Internet identifiers, and their status as codes for the purpose of blocking gTLD applications seems pointless and unfair.

While not using ISO 3-letter codes may seem a good idea from the point of view of keeping ICANN insulated, that is not the only point of view, and frankly that Rubicon was crossed long ago—as long ago as .gb vs. uk in fact.  There is more to the Internet than ICANN’s convenience and its desire to avoid geopolitical imbroglios.  It makes no sense to me to deny Venice .VEN or Andalusia .AND simply because the ISO used these as postal codes.  It seems unfair and arbitrary and Postel’s desire to stay out of politics has little to do with ICANN, which is highly political.  To suggest that ICANN, full to bursting with politics at every every level, should depoliticize itself in this one particular area, doesn’t make sense to me.

Except for Postel’s use of two-letter codes for ccTLDs, the ISO lists would have been used exclusively for the post, and as far as I know the three-letter codes remain in use for the post only.  If I’m wrong about that, I’d be grateful for a link or an explanation on how they are used on the Internet.  Also, I was unaware that Postel reserved the three-letter codes for TLD usage; again, if you have a reference please send it along.  And I’ve seen Mockapetris quoted in the domain press (DN Journal) that the resistance was to .com, not to the country codes.

In any case, the reasons for reserving the ISO three-letter codes as a “blocking” mechanism escape me.  ISO-labeled territories have their won very powerful advisory committee within ICANN (the GAC) to protect them. I don’t see the aspirations of the Welsh to have their own TLD, with a label that clearly identifies them in their own language, as any more irredentist or nationalist than I see .com as being imperialist.

Let me be clear, even if CYM Phillip Hallam-Baker  –  Nov 9, 2010 12:58 PM

Let me be clear, even if CYM was available, ICANN should not and must not get into the business of legitimizing irredentist factions. That can only end badly.

How about TIB for Tibet?

If that was granted we can be certain that China would block it and that would not be the only action they took against ICANN.

How about KHA for Khalistan?

ICANN can’t start issuing this type of domain without picking sides in disputes it has no business being involved in.

And as for this being “the aspirations of the Welsh to have their own TLD”, no, it is the aspirations of one particular faction. It might very well be the case that a majority of people living in Wales would opposed this proposal. Only 50.1% of the population could even be bothered to vote for a Welsh assembly in the last referendum and the proposal passed 50.3 for to 49.7 against. And that was with the national parties all assuring the population that devolution was not a step towards independence.

ICANN has no business getting involved in these issues. It must avoid any implication that it is in the business of granting recognition to states or pseudo-states.

That cat is well out of the bag with .cat, right? Suresh Ramasubramanian  –  Nov 9, 2010 1:25 PM


There is a solution here Thomas Barrett  –  Nov 9, 2010 4:50 PM

The real motivation behind this restriction is to avoid potential confusion/competition with two-letter ccTLD’s, especially for the same territory.

Presumably these ISO three letter codes are available to the government they are designated for?  So, if Cayman Islands so desired, they could ask that CYM be delegated to them?  They could then, in turn, license the extension to anyone they wished to.

There are some other reserved three-letter strings, such as .GEO or .PER that could be allocated in this fashion.

Tom Barrett

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