Comments from CNNIC,"Paired delegation of Simplified Chinese and Traditional Chinese gTLDs should be allowed!"
To Whom it may concern, We find that the progress on exploring solutions to variant management seems paused and even drawn back according to this AGB. We have growing concerns about whether it's compliant with ICANN's Bylaw to avoid this challenge of variant management (in particular variant involved delegation), especially when it's affecting billions of global users' right of using the Internet. For Chinese users, Simplified Chinese and Traditional Chinese are ONE language and they are identical. Based on millions of Chinese users' right of using the Internet and their usability and readability, we encourage and welcome paired delegation of Simplified Chinese and Traditional Chinese gTLDs. Global Chinese-language users, no matter whether Simplified Chines(SC) or Traditional Chinese(TC) they use, are never so close like now with the help and development of technologies. No doubt Internet is one of the most essential means which help bring global Chinese users together and assist them in accessing rich online information coded in either SC or TC. It is especially true when Chinese using Internet users are distributed across the world. According to Chinese national statistics of international tourist arrivals, in 2009 there were a total of 33.18 million visitors to mainland China from Taiwan, Hong Kong, and Macao; the number of tourists from mainland China to those three regions reached 34.78 million. The number of global overseas Chinese is about 48 million according to a national analysis report in 2008. Considering millions of Chinese users' interest and right of accessing both online content in SC or TC, any attempt to separate SC from TC would constitute a cultural segregation because it shall lead to user confusion and result in the marginalization of millions of users who view SC and TC as essentially identical. On the other hand, allowing SC and TC strings identically adopted as IDN TLDs offers tremendous convenience to Chinese users whose keyboards, input methods, and sometimes display methods support only one or the other. Some research has shown that Chinese users expect both versions of domain names to be held and used by the same registrant. A survey conducted by CNNIC in 2009 indicated that 95 percent of respondents are eager to own pure Chinese domain names. Based on this research, we strongly oppose delegating only one version of a Chinese gTLD to an applicant, which will surely deprive the registry operator, CDN registrants, and Chinese users worldwide of the right to properly use CDNs. Dividing SC and TC or trying to undermine the identicalness of them, would impede millions of Chinese users' use of the Internet when navigating using CDNs. Therefore, we suggest that the AGB should allow the paired delegation of SC and TC gTLDs in order to bring better usability and readability to millions of Chinese users. Sincerely, CNNIC (China Internet Network Information Center) www.cnnic.cn _____