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:
- 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.
- 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]