Every ISO-3166 Alpha-2 two-letter abbreviation of a national name is reserved for the use of the Internet community of that nation as a “country-code Top Level Domain,” or “ccTLD.” This reservation is made expressly for the Internet community of the nation and not the government of the nation. Geographic, political, and sociocultural allocations of “internationalized” top-level domains (such as “.рф” to the Russian Federation, or “.укр” to Ukraine) are made in parallel with the ISO-3166 mechanism.

The primary users of any ccTLD are its civilian constituents, who may be distributed globally and may be united by linguistic or cultural identity rather than nationality or national identity. Removal of a ccTLD from the root zone of the domain name system (the sanction suggested by the letter) would make it very difficult for anyone, globally, within Russia or without, to contact users of the affected domains, a group that consists almost entirely of Russian-speaking civilians. At the same time, it would have relatively little effect upon Russian military networks, which are unlikely to rely upon DNS servers outside their own control.

We therefore conclude that the revocation, whether temporary or permanent, of a ccTLD is not an effective sanction because it disproportionately harms civilians; specifically, it is ineffective against any government that has taken cyber-defense preparatory measures to alleviate dependence upon foreign nameservers for domain name resolution. In addition, any country against which this sanction was applied would likely immediately set up an “alternate root,” competing with the one administered by the Internet Assigned Numbers Authority, using any of a number of trivial means. If one country did so, others would likely follow suit, leading to an exodus from the consensus Internet that allows general interconnection.