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

berlinAll 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:

2-letter-berlin

Sold.Domains

About Konstantinos Zournas

Konstantinos studied Computer Engineering and Computer Science in London and lives in Athens, Greece. He works on domain names, websites and software development. Has been online since 1995 & domaining since 2002.

12 comments

  1. Konstantinos,

    there is nothing wrong with these registrations. dotBERLIN – and other registries – received the „AUTHORIZATION FOR RELEASE OF TWO-CHARACTER LETTER/LETTER ASCII LABELS AT THE SECOND LEVEL“ from ICANN on April 8, 2015, which states:

    „Pursuant to Section 2 of Specification 5 of the Registry Agreement for the above- identified top-level domain, and subject to compliance with all other terms of the Registry Agreement, ICANN authorizes Registry Operator to release for registration to third parties and activation in the DNS at the second level the two-character letter/letter ASCII labels identified in Appendix 1 to this Authorization.“

    https://www.icann.org/sites/default/files/tlds/berlin/berlin-auth-ltr-ltr-08apr15-en.pdf

    Best, Johannes Lenz-Hawliczek, dotBERLIN

    • This authorization means nothing to me. ICANN is known for going against its own rules.
      I have no idea where it came from. GAC has asked for individual registry requests and public comments. I don’t see that.

      How did you get this Letter/Letter Two-Character ASCII Labels on 01 December 2014?
      It makes no sense that these 2-letter domains were released on the same day that ICANN made this announcement “ICANN Finalizes Process for Requests for Release of Two-Character ASCII Labels” that says:
      “Registries seeking to release letter/letter two-character ASCII labels at the second-level will continue to follow a transparent process as recommended by the Government Advisory Committee (GAC).

      Registry operator submits a request to ICANN to release one or more letter/letter two-character ASCII label(s).
      ICANN reviews the request and posts it for comment for 30 days.
      ICANN notifies the GAC of the request and the comment period.
      If there are no relevant and reasoned objections to the request, ICANN will approve the letter/letter ASCII label(s) request within 7-10 calendar days of the close of the 30-day public posting period.

      In accordance to Section 6 of Specification 5 of the Registry Agreement, a list of reserved names for this section are still subject to the reservation requirements and will not be available for release at this time.”

      Unless this is all an ICANN show.

    • @Johannes, why there was no sunrise period for trademark owners? Short trademarks were not part of regular sunrise. Would you mind to explain this?

  2. Check for example AA.berlin.

    Besides of “PUNKTBERLIN GmbH” being listed ad an organization name, Whois shows “Premium-Domain for Sale” as a name of registrant.

    Considering AA being a registered trademark, this registration is clearly a bad faith from the registrant, as it was registered for sale from very first moment.

    And there was no sunrise period for two-letter names, so that is another breach of ICANN rules.

  3. I thought its the same company (punkt means dot). but yeah, maybe its a sister company etc

    “Die PUNKTBERLIN GmbH nimmt als Komplementärin u.a. Tätigkeiten im Rahmen der Geschäftsführung für die dotBERLIN GmbH & Co. KG wahr.”

    “Komplementär” means a person with full action rights (in place of)

    http://punkt.berlin/

    Address is the same:
    Gustav-Mueller-Straße 1

    founder of both are Dirk Krischenowski
    http://dot.berlin/de/team

  4. Seems that many other 2-letter domains were released by ICANN for several New gTLDs. All this was done without the proper procedure and who knows what happened…

  5. Mr. Greece,

    you should shut up if you don’t know what happened. Check this link and you’ll see that “all this was done WITH the proper procedure”:

    https://www.icann.org/resources/two-character-labels/archived-requests/

    GAC had its 2 month comment period and not all LLs were approved.

    What’s your problem and why that panic?

    • Mr No Name,
      you seem to be really irritated about this issue and hiding your name for a reason, I presume.
      This link further proves that there was not a proper procedure with a proper comment period and a government notification.
      You seem to be panicking so please relax and enjoy my next post.

  6. great said konsta lets see who is this spy and what he respond

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