All 2-Letter .Berlin Domain Names Were Registered Against ICANN Rules

All 676 combinations of 2-letter .berlin New gTLD domain names were registered yesterday against ICANN rules that prohibit the registration of all 2-letter domain names in New gTLDs.

Domain names like us.berlin, uk.berlin and aa.berlin have been registered by a single Berlin based company that seems to be a partner of the .berlin registry.

Registration of all 2-character New gTLD domains was initially not allowed by ICANN rules:

All two-character ASCII labels shall be withheld from registration or allocated to Registry Operator at the second level within the TLD. Such labels may not be activated in the DNS, and may not be released for registration to any person or entity other than Registry Operator, provided that such two-character label strings may be released to the extent that Registry Operator reaches agreement with the related government and country-code manager of the string as specified in the ISO 3166-1 alpha-2 standard. The Registry Operator may also propose the release of these reservations based on its implementation of measures to avoid confusion with the corresponding country codes, subject to approval by ICANN.

On the contrary 1-letter new gtld registrations were allowed from the beginning.

Several registries then submitted requests at ICANN for the release for 2-character (eg. 1a, b5 etc), domain names including .berlin. This was part of .berlin’s request:

.berlin – On 1 September 2014, ICANN posted for public information a request made by dotBERLIN GmbH & Co. KG. The proposed service requests the release of all two-character ASCII labels that do not appear on the ISO 3166-1 alpha-2 list and for which there is no corresponding government or country-code operator. The registry operator noted in its RSEP that “Given that there is no relevant government or corresponding country-code operator, there is no way for a Registry operator to obtain permission for the release of such characters. More importantly, the release of these two-character ASCII labels poses no risk of confusion with any country-code. Therefore, the restrictions placed on this set of two-character ASCII labels are unwarranted and should be lifted forthwith”.

ICANN requested public comments on these requests and finally decided that it will release some 2-character domains. Then ICANN announced that it will release all (number/letter, letter/number, number/number) 2-character New gTLD domains.

The remaining two-character ASCII labels, or letter/letter labels, could also be eligible for consideration for “authorization” to be released in the future. The Governmental Advisory Committee (GAC) has developed a process for this release but I am not familiar with any New gTLD that has successfully been allowed to release 2-letter domains.

Some registries have been releasing 2-character domain names. Rightside released 20,000+ 2-character domains last month.

But again no 2-letter (aa, ab etc.) domain name registrations are allowed by ICANN rules.

So how were all 2-letter .berlin domains allowed to be registered yesterday (2015-04-13)?

All 2-letter domains were registered yesterday by a single company name PUNKTBERLIN GmbH (Premium-Domain for Sale). The company appears to be a partner of the .berlin registry as it states in its website: “Die PUNKTBERLIN GmbH nimmt als Komplementärin u.a. Tätigkeiten im Rahmen der Geschäftsführung für die dotBERLIN GmbH & Co. KG wahr.”

But even if this company is a partner of the .berlin registry this doesn’t mean that these registrations are not against ICANN rules that clearly state: “Such labels may not be activated in the DNS, and may not be released for registration to any person or entity other than Registry Operator, provided that such two-character label strings may be released to the extent that Registry Operator reaches agreement with the related government and country-code manager of the string as specified in the ISO 3166-1 alpha-2 standard.”

First of all the domains are not allowed to be registered to any other entity except for the registry. PUNKTBERLIN GmbH is not the registry. Other registries such as Uniregistry is doing such registrations but they do them on domains that are allowed to be registered.

Second, these should not be activated in the DNS. While some domains seem inactive because they have no nameservers and don’t appear in the zone files, a lot of domains do have nameservers. I chacked today’s zone file and found several 2-letter domains such as ab.berlin, zy.berlin and nd.berlin. These domains have nameservers but don’t resolve yet.

Finally, all 2-letter domain names were registered including country-codes specified in the ISO 3166-1 alpha-2 standard. The request made by the .berlin registry to ICANN clearly stated: “The proposed service requests the release of all two-character ASCII labels that do not appear on the ISO 3166-1 alpha-2 list and for which there is no corresponding government or country-code operator.”

The same company registered all 1-character .berlin domains too but these are allowed by ICANN.

All domain names were registered at the German registrar PSI-USA, Inc. dba DOMAIN ROBOT.

The .berlin official registry website mentions 2-character domain names in the premium domain name section and says that non are available at this time. Here is what the website says (translated by Google translate):
“What is true for others, also applies to us : The ICANN has something to say . Due to their defaults all possible domains are not the same available to the start. The locked by ICANN domains include country names and -abkürzungen , 2 characters , locked collisions due to technical terms and names of the IOC , the Red Cross and other not-for – profit organizations. But many of these domains are expected to be registerable at a later date .”

It’s kinda funny that .berlin is advertising these registrations at its official website at the latest registrations section: