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Former NTIA chief Redl now working for Amazon

Kevin Murphy, November 6, 2019, Domain Policy

David Redl, the former head of the US National Telecommunications and Information Administration has joined Amazon as an internet governance advisor, I’ve learned.

I don’t know whether he’s taken a full-time job or is a contractor, but he’s been spotted palling around with Amazon folk at ICANN 66 in Montreal and knowledgeable sources tell me he’s definitely on the payroll.

Redl was assistant secretary at the NTIA until May, when he was reportedly asked to resign over a wireless spectrum issue unrelated to the domain names after just 18 months on the job.

His private sector career prior to NTIA was in the wireless space. I don’t believe he’s ever been employed in the domain industry before.

NTIA is of course the US agency responsible for participating in all matters ICANN, including the ongoing fight over Amazon’s application for the .amazon brand gTLD.

The proposed dot-brand has been in limbo for many years due to the objections of the eight nations of the Amazon Cooperation Treaty Organization, which claims cultural rights to the string.

ACTO nations on ICANN’s Governmental Advisory Committee want ICANN to force Amazon back to the negotiating table, to give them more power over the TLD after it launches.

But the NTIA rep on the GAC indicated at the weekend that the US would block any GAC calls for .amazon to be delayed any longer.

As I type these words, the GAC is debating precisely what it should say to ICANN regarding .amazon in its Montreal communique, using competing draft texts submitted by the US and European Commission, and it’s not looking great for ACTO.

As I blogged earlier in the week, another NTIA official, former GAC rep Ashley Heineman, has accepted a job at GoDaddy.

UPDATE: As a commenter points out, Redl last year criticized the revolving door between ICANN and the domain name industry, shortly after Akram Atallah joined Donuts.

America has Amazon’s back in gTLD fight at ICANN 66

Kevin Murphy, November 3, 2019, Domain Policy

The United States looks set to stand in the way of government attempts to further delay Amazon’s application for .amazon.

The US Governmental Advisory Committee representative, Vernita Harris, said today that the US “does not support further GAC advice on the .amazon issue” and that ICANN is well within its rights to move forward with Amazon’s controversial gTLD applications.

She spoke after a lengthy intervention from Brazilian rep Ambassador Achilles Zaluar Neto, who said South American nations view the contested string as their “birthright” and said ICANN is allowing Amazon “to run roughshod over the concerns and the cultural heritage of eight nations and tens of millions of people”.

It was the opening exchange in would could prove to be a fractious war of words at ICANN 66 in Montreal, which formally opens tomorrow.

The .amazon applications have been controversial because the eight countries in the Amazon Cooperation Treaty Organization believe their unwritten cultural rights to the word outweigh Amazon’s trademark rights.

Forced to the negotiating table by ICANN last year, the two sides each posed their own sets of ideas about how the gTLD could be managed in such a way as to protect culturally sensitive terms at the second-level, and taking ACTO’s views into account.

But an ICANN-imposed deadline for talks to conclude in April was missed, largely as a result of the ongoing Venezuela crisis, which caused friction between the ACTO governments.

But today, Brazil said that ACTO is ready and willing to get back to the negotiating table asked that ICANN reopen these talks with an impartial mediator at the helm.

As things stand, Amazon is poised to get .amazon approved with a bunch of Public Interest Commitments in its registry contract that were written by Amazon without ACTO’s input.

Neto said that he believed a “win-win” deal could be found, which “would provide a positive impetus for internet governance instead of discrediting it”. He threatened to raise the issue at the Internet Governance Forum next month.

ICANN’s failure to reopen talks “would set a bad precedent and reflect badly on the current state of internet governance, including its ability to establish a balance between private interests and public policy concerns”, he said

But the US rallied to Amazon’s defense. Harris said:

The United States does not support further GAC advice on the .amazon issue. Any further questions from the GAC to the Board on this matter we believe is unwarranted… We are unaware of any international consensus that recognizes inherent governmental rights and geographic names. Discussions regarding protections of geographic names is the responsibility of other forums and therefore should be discussed and those relevant and appropriate forums. Contrary to statements made by others, it is the position of the United States that the Board’s various decisions authorizing ICANN to move forward with processing the.application are consistent with all relevant GAC advice. The United States therefore does not support further intervention that effectively works to prevent or delay the delegation of .amazon and we believe we are not supportive and we do not believe that it’s required.

This is a bit of a reversal from the US position in 2013.

Back then, the GAC wanted to issue consensus advice that ICANN should reject .amazon, but the US, protecting one of its largest companies, stood in the way of full consensus until, in the wake of the Snowden revelations, the US decided instead to abstain, apparently to appease an increasingly angry Brazil.

It was that decision that opened the door to the six more years of legal wrangling and delay that .amazon has been subject to.

With the US statement today, it seems that the GAC will be unlikely to be able to issue strong, full-consensus advice that will delay .amazon further, when it drafts its Montreal communique later in the week.

The only other GAC member speaking today to support the US position was Israel, whose rep said “since it is an ongoing issue for seven years, we don’t believe that there is a need for further delay”.

Several government reps — from China, Switzerland, Portugal, Belgium and the European Commission — spoke in favor of Brazil’s view that ICANN should allow ACTO and Amazon back to the negotiating table.

The GAC is almost certain to say something about .amazon in its communique, due to drop Wednesday, but the ICANN board of directors does not currently have an Amazon-related item on its Montreal agenda.

UPDATE: The originally published version of this story incorrectly identified the US GAC representative as Ashley Heineman, who is listed on the GAC’s web site as the US representative. In fact, the speaker was Vernita Harris, acting associate administrator at the US National Telecommunications and Information Administration. Had I been watching the meeting, rather that just listening to it, this would have been readily apparent to me. My apologies to Ms Heineman and Ms Harris for the error.

Hindu god smites Chrysler gTLD

Kevin Murphy, October 11, 2019, Domain Policy

Car-maker Chrysler has withdrawn its application for the .ram dot-brand gTLD more than six years after receiving a government objection on religious grounds.

Ram is a brand of pickup trucks manufactured by Chrysler, but it’s also a variant spelling of Rama, an important deity in the Hindu pantheon.

Back in 2013, ICANN’s Governmental Advisory Committee forwarded an objection from majority-Hindu India, later saying: “The application for .ram is a matter of extreme sensitivity for the Government of India on political and religious considerations.”

In a 19-page response (pdf), Chrysler said that Ram vehicles had been around for 75 years without offending Hindus, and that .ram was to be a restricted dot-brand that could not be used by third parties to post offensive content.

The objection appeared at a time when the GAC was not obliged to show its thinking and often deliberately obfuscated its advice. But ICANN placed .ram on hold anyway, where it has remained ever since.

Over the intervening time, Chrysler has rethought its dot-brand strategy, and last month called on ICANN to cancel five of the six gTLDs it already owns (but does not use) — .chrysler, .dodge, .mopar, .srt and .uconnect.

It’s still contracted to run .jeep, weirdly.

Correction: the 10 most-used dot-brands

Kevin Murphy, October 1, 2019, Gossip

Regular readers may recall that back in May DI published an article entitled “These are the 10 most-used dot-brands”.

It turns out the article, which looked at how 10 dot-brand gTLDs were being used, was based on bad data — the result of a single-character typo in the software I used to compile the data.

It was just dead wrong. I’ve therefore deleted the post.

It’s DI policy to always correct articles when errors are discovered, and to issue full corrections, such as this one, for particularly egregious balls-ups.

Sorry about that.

Bumper batch of dot-brands off themselves for Friday 13th

Kevin Murphy, September 12, 2019, Domain Registries

It’s Friday 13th tomorrow, and to celebrate the occasion no fewer than 13 dot-brands have opted to take the easy way out and self-terminate.

ICANN has published a bumper list of contracted brand registries that have informed the organization that they no longer wish to run their gTLDs.

Adding themselves to the dot-brand deadpool are: .ladbrokes, .warman, .cartier, .piaget, .chrysler, .dodge, .mopar, .srt, .uconnect, .movistar, .telefonica, .liason and .lancome.

That brings the total of self-terminated new gTLDs to date to 66.

The imminent demise of .cartier and .piaget is perhaps notable, as it means luxury goods maker Richemont has now abandoned ALL of the nine dot-brands it originally applied for.

Richemont, an enthusiastic early adopter of the new gTLD concept, applied for 14 strings in total back in 2012.

The only ones it has left are generics — .watches along with the the Chinese translation .手表 and the Chinese for “jewelry”, .珠宝, none of which have been launched and in all likelihood are being held defensively.

It’s the same story with L’oreal, the cosmetics company. It also applied for 14 gTLDs, mostly brands, but abandoned all but .lancome prior to contracting.

With .lancome on its way out, L’oreal only owns the generics .skin, .hair, .makeup and .beauty, at least one of which is actually being used.

Also of note is the fact the car company Chrysler is dumping five of its six gTLDs — .chrysler, .dodge, .mopar, .srt and .uconnect — leaving only .jeep (unused) still under contract.

Clearly, Chrysler is not as keen on dot-brands as some of its European competitors, which have been among the most prolific users.

Telefonica’s abandonment of .movistar and .telefonica also means it’s out of the gTLD game completely now, although its Brazilian subsidiary still owns (and uses) .vivo.

Betting company Ladbrokes only ever owned .ladbrokes, though it did unsuccessfully apply for .bet also.

Rounding off the list is .warman, a brand of — and I’m really not making this up — industrial slurry pumps. The pumps are made by a company called Weir, which uses global.weir as its primary web site. So that’s nice.

As far as I can tell, none of the gTLDs that are being killed off had ever been used, though each registry will have paid ICANN six-figure fees since they originally contracted.

Another victory for Amazon as ICANN rejects Colombian appeal

Kevin Murphy, September 9, 2019, Domain Registries

Amazon’s application for .amazon has moved another step closer to reality, after ICANN yesterday voted to reject an appeal from the Colombian government.

The ICANN board of directors voted unanimously, with two conflict-related abstentions, to adopt the recommendation of its Board Accountability Mechanisms Committee, which apparently states that ICANN did nothing wrong when it decided back in May to move .amazon towards delegation.

Neither the board resolution nor the BAMC recommendation has been published yet, but the audio recording of the board’s brief vote on Colombia’s Request for Reconsideration yesterday can be found here.

As you will recall, Colombia and the seven other governmental members of the Amazon Cooperation Treaty Organization have been trying to stymie Amazon’s application for .amazon on what you might call cultural appropriation grounds.

ACTO governments think they have the better right to the string, and they’ve been trying to get veto power over .amazon’s registry policies, something Amazon has been strongly resisting.

Amazon has instead offered a set of contractual Public Interest Commitments, such as giving ACTO the ability to block culturally sensitive strings, in the hope of calming the governments’ concerns.

These PICs, along with Amazon’s request for Spec 13 dot-brand status, will likely be published for 30 days of public comment this week, Global Domains Division head Cyrus Namazi told the board.

Expect fireworks.

After comments are closed, ICANN will then make any tweaks to the PICs that are necessary, before moving forward to contract-signing with Amazon, Namazi .said.

Why you should never let a pizza joint apply for your billion-dollar dot-brand

Kevin Murphy, September 9, 2019, Domain Registries

A multi-billion dollar telecoms company has lost its two dot-brand gTLDs after apparently hiring a failed pizza restaurant to manage them.

For reals.

Several times a year, my friends at other domain news blogs will post cautionary tales about companies losing their domains after falling out with the consultant or developer who originally registered the names on their behalf.

I believe this story is the first example of the same thing happening at the top level, with two valuable dot-brand gTLDs.

It concerns the Saudi Arabian telco Etihad Etisalat, which does business as Mobily. It’s publicly traded, with millions of subscribers and 2018 revenue of the equivalent of $3.14 billion.

The two gTLDs we’re concerned with are .mobily and موبايلي. (.xn--mgbb9fbpob), the Arabic version of the brand.

Back in 2012, a Bahrain company called GreenTech Consultancy Company applied for both of these TLDs. The applications made it explicit that they were to be single-registrant dot-brands to be used by Mobily.

Quite what the relationship between Mobily and GreenTech was — if there even was one — isn’t particularly clear.

GreenTech’s shareholders were Anwar Ahmed and Asma Malik, two Pakistani nationals living in Bahrain, according to Bahrain business records.

Its web site is an laughable mess of broken English, shameful grammar, irrelevant and impenetrable technobabble (much of which appears verbatim on several other South Asian tech companies’ web sites), and a suggestion that the company is primarily in the business of selling satellite modems.

The site just stinks of bogosity. It looks like a dirt-cheap developer threw the site together during his lunch break for beer money.

Bahrain company records show that GreenTech shared a registration with a company called Greentech Pizzeria Restaurant. Same two directors, same address, same company number.

The consultancy company was formed in February 2012 — during the ICANN application window — and the pizza joint opened a bit over a year later.

Why a multi-billion dollar telecommunications company would entrust its brands to these guys, if that is in fact what happened, is a bit of a mystery.

From information that has recently emerged, which I’ll get to shortly, it appears that the true applicant was a Los Angeles-based gTLD consultancy called WiseDots, which in 2011 was co-founded by recently departed ICANN CFO Kevin Wilson and Herman Collins.

WiseDots employees Collins, Wael Nasr and Alan Bair were all at some point listed as primary or secondary contacts for the two applications, as was domain lawyer Mike Rodenbaugh of Rodenbaugh Law.

Wilson left WiseDots in May 2012 and rejoined three years later as CEO after a stint at Donuts. He’s currently listed as the Admin contact for both Mobily gTLDs in the IANA records.

It appears that Mobily signed a letter of intent with WiseDots on April 9, 2012, just three days before the ICANN application window closed, and that was later formalized into a contract in 2014, six months before GreenTech signed its contracts with ICANN.

Both applications made it through ICANN’s evaluation process with apparently no trouble — there were no objections on trademark or any other grounds — and the Registry Agreements were signed in December 2014.

It’s worth noting that neither contract contains Specification 13, which is required for a registry to operate as a dot-brand. If you want to run a dot-brand, you have to show ICANN that you own a trademark matching the string you’ve applied for.

GreenTech did actually submit requests for Spec 13 approval (pdf) — a week after the contracts were already signed — but at a later date both were either withdrawn or rejected by ICANN for reasons unknown.

Both requests include what appear to be scans of Saudi trademark certificates, but they’re both in Arabic and I’ve no idea who they’re assigned to. Presumably, Mobily, which may explain why GreenTech couldn’t get its Spec 13.

After the contracts were signed, it took exactly one full year — the maximum delay permitted by ICANN — before they were delegated and entered the DNS root.

A year after that, in December 2016, ICANN whacked GreenTech with a breach-of-contract notice (pdf), after the company apparently failed to pay its ICANN fees.

The fees had been “past due” for at least six months. It seems quite possible GreenTech had never paid its fees after delegation.

The breach was later escalated to termination, and the two parties entered mediation.

According to Nasr, in a letter to ICANN, Mobily had promised to pay the ICANN fees, but had reneged on its promise, causing the breach.

The issue was resolved, with GreenTech apparently agreeing to some “confidential” terms with ICANN, in November 2017.

It has now transpired, from Nasr’s letter and attached confidential joint-venture agreement, that GreenTech, WiseDots, Collins, Ahmad, Nasr and yet another consultant — an Egyptian named Ahmed El Oteify, apparently with Varkon Group — made a pact in August 2016 whereby the two gTLDs would be transferred into the control of a new jointly owned Bahrain company to be called MobileDots WLL, which in turn would be owned by a new jointly owned Delaware company called MobileDots LLC.

The TLD contracts would then be transferred to Mobily, according to Nasr.

“GreenTech and the two Mobiledots companies were intended to be intermediate conduits for the future transfer of the two Mobily licenses to Mobily as their eventual Registered Operator,” he wrote.

“At no point in time was GreenTech ever contemplated as the true operator of the ‘Mobily’ gTLD licenses. Indeed, GreenTech ran a defunct pizza restaurant, and was long ago de-registered by the Bahraini government for its numerous payments and filing defaults,” he wrote.

The Delaware company was created, but there does not appear to be an official record of the Bahrain company being formed.

According to Nasr, after Mobily stopped paying its ICANN dues the joint venture partners fell out with each other over how to finance the registries. This led to GreenTech asking ICANN to terminate its contracts, which I blogged about in May.

As is customary when a brand registry self-terminates, ICANN made a preliminary decision not to transfer the GreenTech contracts to a third party and opened it up to public comments.

Nasr’s letter is the first example of anyone ever actually using that public comment opportunity.

He argued that because of the JV agreement, ICANN should instead transfer .mobily and the Arabic version to MobileDots.

ICANN declined, saying “it is not within the remit of ICANN org to transfer the TLDs to a specific successor Registry Operator (such as Mobiledots L.L.C., as Mr. Nasr requests) through this termination process”.

As a further twist in the tale, on August 23 this year, just four days before the contract terminations were due to become effective, GreenTech withdrew its requests for reasons unknown.

But it seems ICANN has had enough.

Last Thursday, it told GreenTech (Wilson and Ahmed) that it is terminating its registry contracts anyway, “invoking certain provisions set forth in the previously agreed-upon confidential terms between ICANN org and GreenTech”.

Its termination notices do not reveal what these “confidential terms” are.

But, given that GreenTech stopped existing as a legal entity in February (according to Bahrain company records) it appears it would have been on fairly solid grounds to terminate anyway.

ICANN’s decision is not open for comment this time around, and IANA has been asked to delete both TLDs from the root as soon as possible.

The upshot of all this is that a massive Saudi telco has lost both of the dot-brands it may or may not have wanted, and a whole mess of gTLD consultants appear to be out of pocket.

And the moral of this story?

Damned if I know. Something to do with pizzas, probably.

The Amazon is burning. Is this good news for .amazon?

Kevin Murphy, August 26, 2019, Domain Policy

With the tide of international opinion turning against Brazil due to the ongoing forest fires in the Amazon, could we see governments change their tune when it comes to Amazon’s application for .amazon?

A much higher number of forest fires than usual are currently burning in the region, largely in Brazil, which critics led by environmentalists and French president Emmanuel Macron have blamed on relaxed “slash and burn” farming policies introduced by new Brazilian president Jair Bolsonaro.

The rain forest is an important carbon sink, said to provide 20% of the world’s oxygen. The more of it is lost, the harder it is to tackle climate change, the argument goes.

It’s been an important topic at the Macro-hosted G7 summit, which ends today. Even the bloody Pope has weighed in.

Arguably, the stakes are nothing less than the survival of human civilization and life on Earth itself.

And this is a story about domain names. Sorry. This is a blog about domain names. My hands are tied.

Amazon the company has been fighting governments over its application for .amazon, along with the Chinese and Japanese translations, for over six years.

ICANN’s Governmental Advisory Committee was responsible for killing off .amazon in 2013 after it decided by consensus that Amazon’s application should not proceed.

That decision was only reached after the US, under the Obama administration, decided to abstain from discussions.

The US had been protecting Amazon by blocking GAC consensus, but changed its tune partly in order to throw a bone to world leaders, including then-president of Brazil Dilma Rousseff, who were outraged by CIA analyst Edward Snowden’s revelations of widespread US digital espionage.

After ICANN dutifully followed the GAC advice and rejected Amazon’s gTLD applications, Amazon appealed via the Independent Review Process and, in 2017, won.

The IRP panel ruled that the GAC’s objection had no clear grounding in public policy that could be gleaned from the record. It told ICANN to re-open the applications and evaluate them objectively.

Ever since then, the GAC’s advice to ICANN has been that it must “facilitate a mutually acceptable solution” between Amazon and the eight nations of the Amazon Cooperation Treaty Organization.

ICANN has been doing just that, or at least attempting to, for the last couple of years.

But the two parties failed to come to an agreement. ACTO wants to have essential veto power over Amazon’s use of .amazon, whereas Amazon is only prepared to offer lists of protected names, a minority position in any policy-setting body, and some sweeteners.

In May this year, ICANN’s board of directors voted to move .amazon along towards delegation, noting that there was “no public policy reason” why it should not.

In June, the government of Colombia filed a Request for Reconsideration with ICANN, demanding it reevaluate that decision.

The RfR was considered by ICANN’s Board Accountability Measures Committee at its meeting August 14, but its recommendation has not yet been published. I’m expecting it to be posted this week.

There’s still opportunity for the GAC to cause mischief, or act as a further delay on .amazon, but will it, in light of some country’s outrage over Brazil’s policy over the rain forest?

One could argue that if the nation that has the largest chunk of Amazon within its borders seems to have little regard to its international importance, why should its claim to ownership of the string “amazon” get priority over a big brand that has offered to protect culturally significant words and phrases?

Remember, as the example of the US in 2012/13 shows us, it only takes one government to block a GAC consensus. If Brazil or Peru continue to pursue their anti-Amazon path, could France throw a spanner in the works, smoothing .amazon’s road to delegation?

Anything’s possible, I suppose, but my feeling is that most governments back ACTO’s position largely because they’re worried that they could find themselves in a similar position of having to fight off an application for a “geographic” string in the next gTLD application round.

.amazon frozen AGAIN as endless government games continue

Kevin Murphy, June 25, 2019, Domain Policy

Amazon’s application for the .amazon gTLD has yet again been frozen, after a South American government invoked ICANN’s appeals process.

The bid, as well as applications for the Chinese and Japanese versions, were returned to “on-hold” status at the weekend, after Colombia filed a formal Request for Reconsideration, an ICANN spokesperson confirmed to DI.

“The processing toward contracting of the .AMAZON applications has been halted pending the resolution of Request 19-1, per ICANN organization’s normal processes,” the spokesperson said.

This means the applications could remain frozen for 135 days, until late October, while ICANN processes the request. It’s something that has happened several times with other contested gTLDs.

Colombia filed RfR 19-1 (pdf) on June 15. It demands that ICANN reverses its board’s decision of May 15, which handed Amazon a seemingly decisive victory in its long-running battle with the eight governments of the Amazon Cooperation Treaty Organization.

ACTO’s members believe they should have policy control over .amazon, to protect the interests of their citizens who live in the region they share.

To win an RfR — something that hardly ever happens — a complainant has to show that the ICANN board failed to consider pertinent information before it passed a resolution.

In Colombia’s case, it argues that the board ignored an April 7 letter (since published in PDF format here) its Governmental Advisory Committee representative sent that raises some interesting questions about how Amazon proposes to operate its TLDs.

Because .amazon is meant to be a highly restricted “dot-brand” gTLD, it would presumably have to incorporate Specification 13 into its ICANN registry agreements.

Spec 13 releases dot-brands from commitments to registrar competition and trademark protection in exchange for a commitment that only the brand itself will be able to own domains in the TLD.

But Colombia points out that Amazon’s proposal (pdf) to protect ACTO governments’ interests would give the eight countries and ACTO itself “beneficial ownership” over a single domain each (believed to be names such as co.amazon, .br.amazon, etc).

If this means that Amazon would not qualify for Spec 13, it could follow that ICANN’s board made its decision to continue processing .amazon on faulty assumptions, Colombia argues.

Colombia points to the case of .sas, a dot-brand that is apparently shared by two companies that have the same brand, as a possible model for shared management of .amazon.

RfRs are handled by ICANN’s Board Accountability Mechanisms Committee.

BAMC took just a couple of days to rule out (pdf) Colombia’s request for “urgent reconsideration”, which would reduce its regular response time from 90 days to 7 days.

The committee said that because the .amazon applications were being placed back on-hold as part of normal procedure during consideration of an RfR, no harm could come to Colombia that would warrant “urgent” reconsideration.

According to ICANN’s spokesperson, under its bylaws the latest the board can respond to Colombia’s request is October 28.

At a GAC session at the ICANN 65 meeting in Marrakech, taking place right now, several ACTO governments have just spent over an hour firmly and publicly protesting ICANN’s actions surrounding .amazon.

They’re still talking as I hit “publish” on this post.

In a nutshell, they believe that ICANN has ignored GAC advice and reneged on its commitment to help Amazon and ACTO reach a “mutually acceptable solution”.

Brand kills off gTLD that is actually being USED

Two more companies have told ICANN they’ve changed their minds about running a dot-brand gTLD, including the first example of a TLD that is actually in use.

Dun & Bradstreet has said it no longer wishes to launch .duns, and Australian insurance company iSelect has had enough of .iselect.

Both companies filed to voluntarily terminate their ICANN registry agreements in March, and ICANN published its preliminary decision to allow them to do so this week.

While business data provider D&B never got around to using .duns, .iselect has had dozens of active domains for years.

The company started putting domains in its zone file about three years ago and had over 90 registered names at the last count, with about a dozen indexed by Google. That’s a quite a lot for a dot-brand.

It is using domains such as home.iselect, news.iselect and careers.iselect as redirects to parts of its main corporate site, while domains such as gas.iselect, creditcards.iselect and health.iselect send customers to specific product pages.

They all redirect to its main iselect.com.au site. There are no web sites as far as I can tell that keep visitors in the .iselect realm.

I’m pretty certain this is the first example of a voluntary contract termination by a dot-brand that is actually in active use.

There have been 52 such terminations to date, including these two latest ones, almost all of which have been dot-brands that never got out of the barn door.

That’s over 10% of the dot-brands that were delegated from the 2012 gTLD application round.