Campaign Correspondence

Subject: Re: [IANA #1429149] .YE ccTLD - Clarification on Substantial Misbehaviour and Next Steps

Dear Ms. Harrington,

Thank you for your response. We appreciate the clarification regarding ICP-1 and will align our submissions with the ccNSO Framework of Interpretation (FOI) going forward.

We respectfully submit that the .YE situation meets the FOI’s threshold for “substantial misbehaviour,” warranting initiation of a formal review:

1. Security & stability risk (FOI 4.4–4.6). The FOI treats substantial misbehaviour as conduct that imposes serious harm or a “substantial adverse impact on the Internet community” by posing a threat to the stability and security of the DNS. The use of .gov.ye for hostile communications (e.g., hocc.gov.ye) and the configuration of phishing infrastructure (e.g., twitter.com.ye) create ongoing security risks and erosion of trust, precisely the harms contemplated in FOI 4.4–4.6.
2. Local resolution is not viable where the operator is inseparable from an armed group repressing the community. While matters of equity/justice are ordinarily local, the FOI recognizes an exception where security/stability is compromised, which applies here.

Terminology. Consistent with the FOI, we use “Transfer” for a consented change of manager and “Revocation followed by Delegation” where consent is absent.

Process & continuity (FOI 4.7–4.9). Revocation is a last resort after notice and opportunity to cure. If pursued, the IANA Operator should work with significantly interested parties to maintain continuity of resolution until a suitable replacement can assume responsibility. A neutral, time-limited trusteeship would operationalize that continuity and enable a legitimate, community-led process to identify a permanent local operator.

Precedent. IANA and the ICANN Board have acted in conflict-affected contexts (e.g., .SO in 2009), documenting rationale and safeguards. We believe .YE merits a similarly careful, transparent process.

Requests
• Please confirm the applicable path (Revocation followed by Delegation) and the documentation you require from significantly interested parties for a temporary neutral trusteeship.
• To ensure our formal application is fully compliant, we request a brief procedural call with PTI/IANA Root Zone Management ([email protected]) to clarify required materials, evaluation milestones, and continuity expectations before we convene Yemeni technical and civil society stakeholders.
• Kindly acknowledge the intended timeline for a formal response in line with ICANN’s Correspondence Process (target: 30 days).

For transparency, we intend to publish your reply and this follow-up. We can promptly provide technical exhibits and affidavits underpinning the security/stability concerns and a continuity runbook suitable for a neutral trusteeship.

Sincerely,

Lead Coordinator
For the FreeTheDotYE Campaign
freethedotye.org | @freethedotye
[email protected]

Subject: [IANA #1429149] Request for Review and Redelegation of the .YE ccTLD due to Governance Failure and Lack of Community Representation

Dear requester,

Thank you for your request seeking to transfer the .YE country-code top-level domain (ccTLD) to an unspecified new manager.

IANA processes ccTLD delegation, transfer, and revocation requests in accordance with established policies and procedures, applying the same framework to all cases. The foundational principles are set out in RFC 1591, which describes the responsibilities of ccTLD managers as trustees serving the local Internet community. The ccNSO’s Framework of Interpretation provides further guidance on the application of RFC 1591. ICP-1, which you referenced, was rescinded more than a decade ago and is not applicable.

Revocation and transfer requests require careful evaluation against established criteria, and current policies do not allow for bypassing due process to effect a revocation or transfer of a ccTLD immediately, unilaterally, or on a temporary basis. Revocation is permitted only where a ccTLD manager has engaged in substantial misbehavior that threatens the stability or security of the DNS and continues after notice and a reasonable opportunity to cure. Such misbehavior is narrowly defined in policy, and matters of equity, justice, honesty, or general competency are expected to be resolved locally.

If a revocation were to occur, in order to retain continuity of operations of the domain, it would need to be associated with a delegation to a new ccTLD manager that demonstrates it meets the established criteria for managing a ccTLD. These include broad support from the local Internet community, administrative and technical competence, and the ability to serve the local Internet community in a fair and equitable manner. Should you wish to pursue this to a specific entity, we would require you to submit a complete application that addresses all relevant areas of assessment.

Our team is available at [email protected] to answer any questions you may have.

Kind regards,

– Selina Harrington IANA Operations Manager

Dear IANA Functions Operator,

We request that ICANN and IANA initiate a formal review of the delegation of Yemen’s country-code top-level domain (.YE) and proceed to redelegate it in accordance with RFC 1591 and ICP-1, because the current operator no longer serves the local Yemeni Internet community as a whole.

Basis in ICANN/IANA policy and practice

RFC 1591 establishes that a ccTLD manager “is a trustee for the delegated domain, and has a duty to serve the community” and must be equitable, just, honest, and competent for the entire local community [1].

ICP-1 (ICANN’s Internet Coordination Policy) outlines evaluation criteria for (re)delegations, including service to the local Internet community, operator competence/neutrality, and the overarching public interest [2].

IANA Root Zone Database lists TeleYemen as the .YE manager [3]. Since 2015, TeleYemen’s infrastructure has operated under Houthi militia control following the takeover of Sana’a, meaning .YE’s effective governance is under a non-state armed group, not community-representative institutions [4].

Demonstrable governance failures

Failure to serve the local Internet community (RFC 1591)

The .YE namespace excludes the internationally recognized government, independent institutions, and civil society, who are forced onto generic TLDs (.com, .net, .org). Meanwhile, militia-run portals occupy .gov.ye, .edu.ye, .net.ye, and .com.ye. This is not community-wide service; it is service to a single faction. [3][4][5]

Loss of neutrality and use of .YE for propaganda and information control

Under .YE, sites such as saba.ye and mmy.ye disseminate militia messaging while the same authority wields control over telecommunications to censor, surveil, and hack activists and NGOs—contrary to the neutrality and public-interest duties of a ccTLD trustee. [5][6][7][8]

Human-rights-linked risks that undermine trust and stability

Documented patterns include abduction, detention, and killing of independent journalists, as well as detentions of UN/NGO staff in areas under militia control. A ccTLD manager associated with such abuses cannot be considered a trusted or stable steward of a national namespace. This degrades trust in .YE locally and internationally and raises DNS-wide concerns. [9][10][11]

Requested action (within ICANN’s mandate under ICP-1)

1. Initiate a formal IANA review of the current .YE delegation against RFC 1591/ICP-1 criteria (community service, neutrality, competence, public interest).
2. Temporarily redelegate .YE to a neutral international trustee (e.g., an agreed independent operator under ICANN/IANA supervision) until a stable, legitimate, and representative national authority exists to assume stewardship.
3. Affirm the core principle that a ccTLD must serve the entire local Internet community, not a single armed faction, and that the DNS must not normalize militia control of national identifiers.

We are prepared to supply additional documentation and to facilitate contact with Yemeni civil-society groups and technical stakeholders who can attest to the exclusionary and repressive operation of .YE under the current arrangement.

Sincerely,

FreeTheDotYE Campaign
[email protected]
https://freethedotye.org

References

• [1] Postel, J. RFC 1591: Domain Name System Structure and Delegation (1994).
• [2] ICANN. ICP-1: Internet Domain Name System Structure and Delegation (ccTLD Delegation and Redelegation).
• [3] IANA Root Zone Database — .YE (Manager: TeleYemen).
• [4] Wilson Center, “Who Are Yemen’s Houthis?” (overview of the 2014–2015 takeover and control of Sana’a).
• [5] saba.ye (Houthi-run SABA “state” outlet); mmy.ye (Houthi military media portal).
• [6] ARTICLE 19 & allied NGOs: Statements on Internet blocking and censorship in Yemen.
• [7] Counter-Extremism/technical reporting on Telecom control enabling surveillance in Houthi-held areas.
• [8] Civil-society/technical analyses linking TeleYemen control to censorship/monitoring.
• [9] CPJ / RSF reports: kidnapping, detention, and killing of journalists in areas under Houthi control (incl. spikes reported in 2025).
• [10] AP / HRW: Detention of UN and NGO staff by Houthis (multiple incidents 2024–2025).
• [11] ICP-1 practice notes and past IANA cases (e.g., .SO redelegation) demonstrating action when a ccTLD fails to serve its local community.