Module 2 comments

["S. Subbiah" <subbiah@xxxxxxxxx>]

2.1.1.1 (same comment in conjunction with 3.1.1) If we pursue down this 
path, and assuming that meaning similarity across languages can even be 
defined,
the equivalent IDN meaning of every current existing ASCII gTLD in every 
IDN script will end up being either
blocked for use by anyone or operated by the exisisng ASCII gTLD 
operator. At the same time, maybe 500 new ASCII
gtLDs (Paul Twomey was quoted widely) may be issued, all representing 
500 new meanings,and they will proceed
to become existing TLD operators for the next round. And at the next 
round these 500 operators (and some
IDN operators that may have also been issued gTLDs) will under these 
same rules collectively ensure that
they "own" these 500 or more meanings in every IDN script ( for the IDN 
operators, all other IDN scripts).
So by the end of thsi first round, where only those who can spend a few 
hundred thousand dollars can particpate,
pretty much all terms of any possible value as a gTLD will have been 
land-grabbed already in every script
by in practice mostly companies from Western/rich/incumbent countries. 
An identical scenario can be imagined
for "sound similarity". By the time 500 ASCII gTLDs are issued for some 
meaning or other, it is quite likley
many many words highly meaningful words in a wide array of IDN 
scripts/languages that may have nothing to do
with the 500 issued ASCII meanings may forever be off-limits for use by 
the people's of those unfortunate hundreds
of Unicode languages (let alone the thousands that one day make it to 
Unicode). As per the near-uananimous
GNSO IDN Working Group Recommednation, the strong Katoh IDN COmmitee 
recomendation from several years ago, public
minuted utterances by the gNSO chairs and Seniro ICANN staff it is very 
clear that the only rational string confusion
to be allowed is a simple visual one - and even then only when it is 
very likley to decieve the end-user. For reasons
that hardly anyone in the IDN community can fathom, IcANN has insisted 
on leaving the wording regqarding this vague until this version.
ANd now it has gone the further step of making it explicit (in 
connection with the joint outcome of String Confusion step and
Legal Rights objection steps) - basically if you alraedy operate or get 
to operate a TLD of a given meaning or sound in
a single script (for now de facto  ASCII) you will own rights (or at 
least prevent others) to that meaning or sound in every
IDN script now in Unicode or the thousands that may one day be 
introduced into Unicode.

2.1.1.3.2 The case and need for one or two character IDN TLDs, 
particularly for the scripts that use ideographs and account for some 
30% of the current
Internet users, was closed long long ago based on unanimous 
recomendation by the GNSO IDN Working Group Report. It is completely 
inconcievable that
even at this current version of the document, we are even debating this. 
Clearly that Working Group's recomendations, like the recomednations of the
Katoh IDN committe of years ago are long forgotten and for those of us 
who stayed up at night to participate it in them for weeks it was just a 
dream.

2.1.1.4.1 & .2 Countries have or will be getting ASCII and IDN ccTLDs 
for their unrestricted use. Additionally it may make some sense to 
prevent other
versions of the country names (or perhaps even their capital city names) 
from being abused by requiring a simple non-objection letter from relevant
government authorities. But to go beyond that and try to protect every 
state, region, town and maybe even village names and their nicknames 
(i.e. New York is
Big Apple), and every fragment of eac name, in every ID script is going 
too far. When combined with an onerous requirment for the non-objection 
letter
to state that the relevant Minister or President understands all of 
ICANN's many rules and financial liabilities and is tacitly "approving 
it" not only
opens up the perception that the goverment is somehow liable later but 
will surely drastiaclly reduce the number of geopolitical TLD applicants 
- the
one area of TLDs which, based on history thus far, might actually find 
some usefulness when the ASCII gTLDs are greatly expanded.   

2.2.1 Limiting technical exchange to a single online event will be 
extremely unfair to non-native English language applicants, whether or 
not translators
and translations are available.