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The ALAC is particularly concerned with the issue of singular vs plural strings. A central issue is that the "confusingly similar" test relies purely on visual similarity. Based on the initial evaluation adding an "S" makes it a recognizably different string. The recent NGPC decision (http://www.icann.org/en/groups/board/documents/minutes-new-gtld-25jun13-en.htm#2.d), re-affirms this position, although several Board NGPC members expressed regret that the wording of the Applicant Guidebook effectively forced this outcome.

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The ALAC disagrees with the NGPC decision. The problem is the belief that "visual similarity" relies purely on what, in computer terminology, would be called "pattern matching". Pattern matching is certainly part of human perception, but it is not limited to that. At issue is whether two strings will be PERCEIVED as being equivalent, and perception is a far more complex (and less understood) issue.

At issue are Consider strings pairs such as:

• hilton.hotel and hilton.hotels;
• soccer.sport and soccer.sports;
• poodle.pet and poodle.pets; and
• taj-mahal.tour and taj-mahal.tours.

Will these be memorably equivalent or different to typical Internet users (the ones who have no knowledge of terms such as ICANN, domain name, TLD and second level)? The ALAC strongly doubts that most Internet users will note the subtle differences.

If both singular and plural TLDs are delegated:

•  Some registrants would register (and defend) their 2^nd level names in both TLDs and map them to the same web and e-mail services. This would reduce the impact on users, but would of course increase costs to registrants (including defensive registrations in both TLDs) who must double their registrations. Moreover, due to either policy differences between the two TLDs, or due to timing constraints, such duplication may not be possible.
• Other registrants would use only one of the TLDs, resulting in quasi-random behavior from a user’s perspective. One cannot expect the typical Internet user to be able to differentiate between two such name spaces, and therefore the ALAC, which is responsible for representing the interests of Internet users in ICANN, believes that we have a genuine case of "confusingly similar."

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