The New gTLD Expansion Round: The Dot Is Making More Friends
4 September 2026
This post examines the evolution and operation of the Internet Corporation for Assigned Names and Numbers (“ICANN”) pre-delegation objection mechanisms, tracing their origins in the 2012 generic Top-Level Domain (“gTLD”) round and their refinement for the new round started in April 2026. It analyses procedural foundations, jurisdictional consent, and the practical application of the four objection grounds, highlighting key case law that is relevant for the new round as well.
In 2012, ICANN announced that “The Dot is Making New Friends!” with the gTLD expansion program at that time. Now, the process of making even more friends has started, with a new round of gTLD expansion kicking off on 30 April 2026.
I. Historical background
The evolution of the Domain Name System (“DNS”) reflects a gradual but significant shift from a tightly controlled naming environment to a vast and commercially dynamic ecosystem.
In the early stages of the Internet, the architecture of top-level domains (“TLDs”) was deliberately limited. During the 1980s, only seven gTLDs were created: <.com>, <.edu>, <.gov>, <.int>, <.mil>, <.net>, and <.org>. Of these, only three—<.com>, <.net>, and <.org>—were “open” domains, available for registration without substantial restrictions [at para 6]. The remaining gTLDs were purpose-specific and restricted: <.int> for international organisations, <.edu> for accredited higher education institutions, <.gov> for U.S. federal government entities, and <.mil> for the U.S. military. Alongside these, <.arpa> was reserved for technical infrastructure purposes.
Parallel to gTLDs, country-code top-level domains (“ccTLDs”) emerged, each corresponding to a two-letter country code under ISO 3166 (e.g., <.fr>, <.de>, <.ro>, <.uk>). These ccTLDs followed diverse regulatory models, with some allowing open registration and others imposing eligibility criteria tied to nationality, residence, or business presence.
The late 1990s marked a turning point. In 1999, a report from WIPO (“World Intellectual Property Organization”) to the ICANN Board recommended the cautious introduction of new gTLDs, emphasizing the need to balance expansion with the protection of intellectual property rights. The rationale for expansion discussed by ICANN at the time rested on three main objectives: increasing competition among registries, enhancing the functional utility of the DNS, and expanding the availability of domain names.
The first expansion round, initiated in 2000, introduced seven new gTLDs, divided into unsponsored domains (<.biz>, <.info>, <.name>, <.pro>) and sponsored domains (<.aero>, <.coop>, <.museum>). The distinction was significant: unsponsored TLDs operated under general ICANN policies, while sponsored TLDs were governed by designated organisations representing specific communities. Notably, ICANN declined at that time to introduce a <.kids> domain, citing concerns about becoming entangled in content regulation.
A second expansion round followed in 2003, focusing exclusively on sponsored gTLDs. This round resulted in domains such as <.post>, <.mobi>, <.asia>, <.travel>, <.tel>, <.cat>, <.jobs>, and eventually <.xxx>. The latter proved particularly controversial, as it raised concerns about ICANN’s role in regulating online content. Although initially rejected, <.xxx> was ultimately approved in 2011 after years of debate.
These early expansion rounds were widely criticised for their lack of transparency, predictability, and procedural consistency. In response, ICANN developed a more structured and rule-based approach, embodied in an Applicant Guidebook, which aimed to provide clear criteria and procedural safeguards for future applicants.
This reform culminated in the landmark 2012 expansion round. For the first time, virtually any string—across languages and scripts—could be proposed as a gTLD. The response was unprecedented: 1,930 applications were submitted, leading to the delegation of over 1,200 new gTLDs. These domains reflected remarkable diversity, encompassing brand names, industries, professions, geographic regions, cultural identifiers, and generic terms. Importantly, the 2012 round also introduced formal objection mechanisms, allowing third parties to challenge applications through structured alternative dispute resolution procedures.
The most recent expansion round of gTLDs began in April 2026, building on the 2012 framework. This post focuses on the objection procedures put in place pre-delegation of new gTLDs, as these were decided in the 2012 expansion round; these are relevant for the objections to be handled in the 2026 round, estimated to start in the last quarter of 2026.
II. Objections, general overview
At the heart of the framework of objections is Module 3 of the 2012 Applicant Guidebook, which sets out both the grounds and procedures for objecting to gTLD applications. This mechanism allows stakeholders to challenge applications on four grounds: string confusion, legal rights, limited public interest, and community interests. Each category reflects a distinct dimension of potential harm, ranging from technical confusion in the DNS to broader concerns of morality, public order, or collective identity.
Between June 2012 and March 2013, third parties actively engaged with this system, filing objections against a wide range of applications.
A distinctive feature of the 2012 framework was the introduction of the Independent Objector (“IO”), tasked with representing the broader public interest rather than a stakeholder. The IO could bring objections in cases where no other party had done so, particularly in relation to community and public interest concerns. However, the role was not without controversy. Challenges to the independence of the IO—most notably in proceedings concerning the <.amazon> string—highlighted structural ambiguities in the framework. Even where doubts about the IO’s independence were raised, panels proceeded to decide cases on the merits due to the absence of clear procedural consequences. These episodes ultimately informed reforms in the 2026 expansion round, where ICANN opted to appoint three IOs to mitigate risks of perceived bias.
The rationale for such a robust objection system is likely tied to the nature of gTLDs themselves. Applicants may seek to operate open registries (e.g., <.music>), geographically themed domains (e.g., <.capetown>), or closed “dot-brand” registries restricted to a specific corporate group. This diversity of models creates significant potential for conflict with existing rights and public expectations. Accordingly, the objection procedures function as preventive mechanisms, intervening before potentially problematic domains are delegated and operational.
The 2012 round resulted in the delegation of over 1,200 gTLDs, illustrating both the scale of the expansion and the importance of effective safeguards. Complementary tools, such as Public Interest Commitments (“PICs”) embedded in registry agreements, and strengthened anti-abuse policies, further reinforced the regulatory framework. Post-delegation mechanisms, including the Uniform Rapid Suspension System (“URS”) and the continued applicability of the UDRP (“Uniform Domain-Name Dispute-Resolution Policy”), ensured that rights protection extended beyond the application phase.
The 2026 expansion round builds on this foundation while introducing notable refinements. These include a new appeal mechanism, enhanced independence safeguards through three IOs instead of one, and procedural innovations such as allowing applicants to propose alternative strings. Substantively, the updated Guidebook also addresses contentious issues from the previous round, including the prohibition of singular and plural variants of the same string in the same language, thereby resolving prior inconsistencies in expert determinations.
As such, in the 2012 round some panels took a relatively strict approach, finding that plural forms were indeed confusingly similar to their singular counterparts. In these cases, panels considered that the addition of an “s” did not sufficiently distinguish the strings and that Internet users could reasonably assume a connection between them. For example, objections involving <.games> vs. <.game>, <.pets> vs. <.pet>, <.sports> vs. <.sport>, and <.tours> vs. <.tour> were upheld on the basis that confusion was probable. On the other hand, other panels acknowledged that some degree of similarity might exist between singular and plural forms, but emphasized that mere similarity is insufficient. Instead, they required concrete evidence that confusion among consumers would be likely or probable, not just theoretically possible. In this vein, objections such as <.tvs> vs. <.tv> and <.hotels> vs. <.hotel> were rejected because the objectors failed to meet the burden of proof regarding the likelihood of confusion. The inconsistency is further illustrated by the <.cars> vs. <.car> disputes, where different panels reached opposite conclusions on essentially the same issue.
III. Procedural aspects
Consent to the expert determination procedure is formed through a dual mechanism: applicants accept the procedure upon filing their application for a new gTLD, while objectors accept it by submitting an objection, thereby subjecting both parties to the jurisdiction of expert panels.
Disputes are administered by specialised dispute resolution service providers (DRSPs), which differ slightly between the two rounds. In 2012, string confusion objections were handled by the International Centre for Dispute Resolution, legal rights objections by the WIPO Arbitration and Mediation Center, and limited public interest and community objections by the International Court of Arbitration of the International Chamber of Commerce (“ICC”). In the 2026 round, WIPO assumes competence for both string confusion and legal rights objections, while the ICC remains responsible for public interest and community objections.
Applicants may respond, settle, or withdraw; failure to respond results in a default decision in favour of the objector. While proceedings remain primarily document-based, the 2026 framework introduces stricter procedural features, including the exclusion of in-person hearings. The objections are resolved via expert determinations that will constitute advice that ICANN will accept within the dispute resolution process.
In the 2026 round, there will be a limited opportunity to challenge certain determinations during evaluation, such as a singular/plural determination, arguing that ICANN made a factual or procedural error. It will also be possible to file an appeal against the expert determination in an Objection process on grounds that the panel made a procedural error or failed to consider or solicit necessary material evidence. Both of these processes will be determined based on a “clearly erroneous” standard.
IV. The four objections
This blog will briefly outline the most significant aspects of the four types of objections provided for in the applicant guidebook, as reflected in the panels’ practice in the 2012 expansion round, and indicate any difference in the new applicant guidebook of 2026, where applicable.
1. String confusion
At its core, a string confusion objection addresses whether an applied-for gTLD is “confusingly similar” to an existing TLD or another applied-for string. The string confusion objection is one of the four objections introduced in the pre-delegation phase of new gTLD applications. First introduced in the 2012 ICANN Applicant Guidebook and preserved in the 2026 round, this objection is designed to prevent the delegation of strings that are likely to confuse Internet users.
The applicable standard is not abstract or theoretical; rather, panels consistently emphasize the perspective of the “average, reasonable Internet user.” Confusion must be probable—not merely possible—and mere association between strings is insufficient (Section 4.5.10.1 2026 Applicant Guidebook).
Standing operates as a low-threshold gateway. Under both the 2012 and 2026 Applicant Guidebooks, objections may be filed by existing TLD operators and applicants in the same round, with the 2026 framework expanding access to ccTLD operators and significantly interested parties. Practice confirms the permissive nature of this requirement: none of the 67 objections in 2012 was rejected for lack of standing. Panels consistently limited their inquiry to whether the objector formally belonged to a recognized category, without assessing the plausibility of confusion at this stage. For example, Verisign successfully objected to strings such as <.ecom> and <.cam> based solely on its operation of <.com>, while Universal Postal Union relied on <.post> to challenge <.epost>. Even tenuous connections sufficed: Commercial Connect, applying for <.shop>, was granted standing to object to strings like <.buy> and <.store>. Similarly, in the <.emerck> case, Merck & Co., Inc. was allowed to rely on a subsidiary’s application, confirming a flexible and non-formalistic approach.
By contrast, the merits stage imposes a rigorous and autonomous standard, centered on whether an average Internet user would probably—rather than possibly—be confused. Panels assess similarity visually, aurally, and semantically, in the abstract and independently of actual use. Case law illustrates this nuanced approach. In the <.cam> vs <.com> dispute, despite visual and phonetic overlap, the objection failed because users would distinguish the well-known commercial connotation of <.com>. Conversely, confusion was found between <.web> and <.webs>, where pluralization was deemed insufficient to prevent user confusion. However, inconsistent outcomes in plural cases (e.g., <.cars> vs <.car> versus <.hotels>) prompted the 2026 rule barring singular/plural coexistence.
Semantic similarity alone has proven insufficient, particularly across scripts. While an objection comparing <.shop> with its Japanese equivalent initially succeeded, it was ultimately rejected due to lack of visual and phonetic resemblance.
Overall, the system balances inclusiveness in access with a cautious, fact-sensitive merits analysis, prioritising both DNS stability and competitive expansion.
2. Legal rights objections
Legal Rights Objections (“LROs”) serve as a key safeguard for trademark holders and other rightsholders against the abusive appropriation of signs at the top level of the Domain Name System. LROs allow objections where an applied-for string would infringe “existing legal rights” recognized under internationally accepted legal principles. While the mechanism is accessible, its practical application in the 2012 round demonstrates a clear asymmetry: permissive standing requirements coupled with stringent, context-driven substantive analysis.
Standing under LROs is deliberately broad. Panels consistently confirmed that it is sufficient for an objector to demonstrate the existence of trademark rights—registered or unregistered—without proving infringement at this stage. This low threshold mirrors the approach under the UDRP. Case practice illustrates this flexibility. In the <.weibo> and <.微博> disputes, panels accepted standing despite ongoing validity challenges to the trademark, emphasizing reliance on the current legal status of rights. Similarly, in <.mls>, certification marks were deemed sufficient, and in <.vip>, licensees were granted standing where licensing relationships were properly evidenced. Panels also rejected territorial limitations, as seen in <.pin>, acknowledging the global nature of the DNS.
However, the merits stage imposes a far more demanding test, reflected in the fact that only four out of 71 filed objections were upheld in 2012. Panels undertake a holistic assessment of factors such as similarity, distinctiveness, intent, and likelihood of confusion. The <.now> objections brought by Starbucks and the <.vip> cases demonstrate that even valid rights will not succeed where the string is descriptive or lacks distinctiveness. Likewise, in <.merck>, competing legitimate rights neutralized exclusivity claims.
The few successful objections highlight the importance of targeting and competitive intent. In <.direct>, the panel found that the application sought to capitalize on a competitor’s mark (DIRECTV), rejecting claims of generic use. In <.delmonte>, the majority considered that the applicant’s conduct breached licensing arrangements and strategically reinforced its application. The <.weibo> cases further illustrate that even descriptive terms may give rise to successful objections where the applicant’s intended use conflicts directly with established trademark rights.
Panels consistently limited their jurisdiction to the applicant’s intended use (in which sense they considered both the uses expressly proposed in the application and any other uses that appear reasonably likely in light of the application materials and surrounding circumstances), excluding speculative second-level uses, which are addressed through other mechanisms such as the UDRP.
Case law in 2012 objections shows a strong presumption in favour of bona fide descriptive or dictionary use. In <.mail> and <.vip>, panels found that the strings would be perceived descriptively—indicating service type or quality rather than source—thus excluding confusion. Similarly, objections to <.food> failed because the applicants’ intended use aligned with the term’s generic meaning, despite existing trademark rights. This reasoning extends to strings such as <.academy>, <.coach>, and <.express>, confirming that common terms intended to be used in their ordinary sense rarely infringe rights. This line of cases most likely mandated the introduction of a new factor for evaluation in the 2026 Applicant Guidebook, namely whether the applicant’s intended use of a common dictionary term that is also a trademark is intended to take advantage of such common meaning or targets a trademark.
3. Limited Public Interest Objections
The Limited Public Interest (“LPI”) objection, introduced by the ICANN Applicant Guidebook in 2012 and retained for the 2026 round, was designed as a safeguard for fundamental values rooted in international law—namely morality and public order. At the heart of the LPI objection lies a closed list of four grounds essentially referring to: incitement to violence, promotion of discrimination, facilitation of child abuse, and contravention of international legal principles. Despite this seemingly wide formulation, panels have consistently interpreted these categories narrowly. Notably, all objections in the 2012 round relied on the fourth, more flexible ground, yet none ultimately succeeded. Panels repeatedly emphasised that the LPI mechanism targets only “particularly reprehensible” conduct, setting a high evidentiary threshold.
This restrictive approach is particularly evident in cases involving health-related strings such as <.health>, <.med>, and <.hospital>. Objectors frequently invoked the right to health under international law, arguing that misuse of such domains could mislead users and undermine trust. Panels acknowledged that human rights norms fall within the scope of LPI objections, but required concrete evidence of probable harm. Abstract risks or speculative concerns were deemed insufficient.
Another key limitation concerns the applicable legal framework. Panels have consistently rejected arguments based solely on national or regional laws. This was clearly illustrated in the <.broker> case, where claims grounded in competition law were dismissed for failing to engage international legal standards.
Finally, panels diverged on the relevance of the intended use of a gTLD. While some experts considered operational context essential (e.g. cases concerning the strings <.health> and <.healthcare>), others focused strictly on the string itself (the <.medical> string case). A balanced approach was taken in the case concerning the string <.hospital>, where intended use was accepted only as a subsidiary consideration.
Ultimately, LPI jurisprudence reflects a clear tension: while access to the mechanism is broad, its substantive scope remains deliberately narrow.
4. Community objections
The community objection is designed to protect clearly identifiable communities from harmful string delegations. Introduced in the 2012 round and retained in the 2026 Applicant Guidebook, it combines relatively broad notions of “community” with strict evidentiary and substantive requirements.
To succeed, an objector must first establish standing as an institution linked to a clearly delineated community. Panels assess factors such as recognition, cohesion, and boundaries, rejecting artificial or opportunistic groupings. On the merits, four cumulative criteria must be met: existence of a defined community, substantial opposition, strong association between the string and the community, and likelihood of material detriment. In practice, the last two—especially material detriment—have proven decisive and difficult to demonstrate.
Empirical results from 2012 highlight this stringency: only 14 of 104 objections succeeded, most failing on the merits. Successful cases typically involved regulated sectors (e.g. <.bank>, <.insurance>, <.architect>) or organized sports communities (e.g. <.sport>, <.rugby>, <.ski>), while more complex or diffuse claims failed.
Panels consistently emphasized their limited mandate. In <.cloud>, they explicitly stated that their role was confined to evaluating the objection and did not extend to assessing the merits of the application itself; in <.map>, they declined to review ICANN eligibility decisions; in <.merck>, they avoided trademark disputes; and in <.shop>, they rejected competition-based arguments. The <.amazon> case further illustrates the high threshold: despite recognized association, the objection failed due to insufficient opposition and lack of proven detriment.
Community objections in the 2012 gTLD round reveal a consistently strict and often decisive approach to standing, centered on the requirement that objectors be “established institutions” associated with a “clearly delineated community.” The Applicant Guidebook’s lack of defining this concept led to divergent panel methodologies, with some merging standing and merits—seen in cases such as <.ski> and <.music>—while others maintained a lower threshold at the admissibility stage, as in <.song>, <.tunes>, and <.merck>. A third approach, illustrated in <.republican>, invoked effet utile to reconcile the dual role of the community requirement.
a. Standing denied
In practice, panels frequently denied standing due to lack of community cohesion. In the <.music> objections, including those by A2IM and IFACCA, panels found no unified “music community,” emphasizing fragmentation and lack of representational authority. Similar reasoning applied in <.band>, <.cloud>, and <.gold>, where industries were deemed too diffuse. In <.book>, Rakuten was recognized as an established institution but failed to demonstrate a qualifying community, while <.map> and <.shop> further illustrate the rejection of loosely defined or overly broad groupings.
The <.merck>decisions clarified that corporate groups cannot constitute communities, and <.republican> highlighted the need for genuine relational ties. Even where standing failed, panels often examined the merits, as in <.book> and <.map>, reinforcing the high substantive threshold.
b. Standing allowed
The 2012 gTLD community objection decisions also reveal a consistent pattern in which panels recognized standing where objectors demonstrated institutional legitimacy, a clearly delineated community, and an ongoing relationship between the two. The <.architect> case confirmed that even contested definitions can suffice if a recognizable professional group exists, while <.bank> emphasized formal institutional structures and sustained engagement through membership-based representation. Similar reasoning applied in <.insurance>, where a broad yet coherent financial services community did not undermine standing.
Industry and sector-specific cases such as <.mobile> and <.fly> demonstrate that panels may refine community definitions to ensure coherence, while still accepting standing where functional links exist. Strongest examples arise in sports cases—<.polo>, <.rugby>, <.ski>, <.sport>, and <.basketball>—where hierarchical governance, international recognition, and clear stakeholder structures readily establish standing.
Beyond these, standing was also recognized for advocacy and identity-based communities (<.gay>), governmental actors (<.halal>), and industry groups (<.hotels>, <.reisen>, <.search>, <.game>). Overall, panels adopted a pragmatic approach, requiring identifiable boundaries and genuine representational links, while accommodating diverse forms of community organization.
c. Independent Objector
The standing IO in community objections operates under a distinct and more permissive regime than that applicable to ordinary objectors. Under the ICANN Applicant Guidebook, the IO is granted standing “notwithstanding the regular standing requirements,” meaning it need not demonstrate association with a clearly delineated community.
Case law shows that panels have examined the scope of this standing and their own authority to review it. In the <.amazon> objections, panels confirmed their jurisdiction to assess challenges to the IO’s independence, relying on inherent powers and the finality of expert determinations. This reasoning was reaffirmed in parallel proceedings concerning the Chinese and Japanese versions of <.amazon>, where panels held that, despite the absence of explicit rules, such challenges fall within their inherent jurisdiction as part of assessing standing.
The <.charity> cases further clarified that the IO’s standing derives solely from its designation, while additional conditions—such as the existence of public opposition—relate to admissibility or merits. Although the objection was initially upheld, it ultimately failed due to lack of demonstrated detriment following regulatory safeguards.
In the healthcare-related <.med> and <.medical> cases, panels accepted the “medical community” as clearly delineated and found substantial opposition. They concluded that insufficient safeguards and narrow governance models created a likelihood of material detriment, illustrating the IO’s substantive role in protecting sensitive sectors.
This overview shows that ICANN’s objection system strikes a careful balance between openness and rights protection, combining accessible standing with rigorous merits review. Some of the issues identified in the 2012 round were addressed in the new Applicant Guidebook of 2026, such as the singular/plural situation, the introduction of an appeal system, or the introduction of three IOs instead of one. The substantive requirements of the objections are largely the same, which is why the determinations in the 2012 round are essential to the new round for all stakeholders.
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About the author:
Mihaela Maravela is an independent arbitrator and counsel based in Bucharest, Romania.
She is an experienced counsel in commercial and investment arbitration, acting under numerous rules, such as ICSID, UNCITRAL, ICC, VIAC, WIPO, CICA-CCIR Rules.
Mihaela sits as arbitrator in domestic and international commercial arbitration and she solved +15 domestic and international commercial arbitrations. She also sits as domain name panelist and she solved over 400 UDRP disputes at the World Intellectual Property Organisation and the Asian Domain Name Dispute Resolution Centre.
She is ranked as a Global Leader in Arbitration and Trademarks since 2018 by Lexology (former WWL).
Mihaela is also experienced in various business sectors such as corporate, M&A, finance & banking, infrastructure, intellectual property, energy, oil & gas, environmental and climate change.
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[1] Editors: Stefanie Efstathiou (Independent Practice) and Mihaela Apostol (ArbTech)
