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Time for ICANN to Protect Existing Registrants of IDN.com against Confusion from Duplication from Transliterations Dot Com

  • To: <comments-base-agreement-29apr13@xxxxxxxxx>
  • Subject: Time for ICANN to Protect Existing Registrants of IDN.com against Confusion from Duplication from Transliterations Dot Com
  • From: "Wrixon David W" <David.W.Wrixon@xxxxxxxxxxxxxxxx>
  • Date: Thu, 2 May 2013 14:23:19 +0100



The main problem I see with the Bottom Up process, so vaunted by
Verisign is that it seems to largely neglect the interests of
Registrants but focuses on the vested interests of the big Registries
and Registrars.


Far from being concerned about future restrictions being place on
Verisign, what I want to see is evidence of them being contractually
committed to undertakings that they have already made as part of the
application procedure.


I accept that the nature of this document is broad and it is potentially
an enabling document for the kind of contractual commitments that I
believe ICANN owes the registrants of IDN.com going back nearly a


It is, however,  wholly unacceptable and against ICANN's own statements
of Mission to allow Audible duplication of domains. In other words, we
have a situation were there is Audible confusion between extentions.
Verisign promised with their application that these domains would
effectively be bundled so that only the owner of the original dot com
can register them. But there is no evidence that there is going to be
any kind of contractual obligation to do so, or even an indication that
there is not going to a massive price differential between English and
other version of dot Com.


Furthermore, even at this late stage there is no clarity of how this
issue is going to be effectively addressed yet alone resolved. Unless
this happens the whole gTLD process, because even none IDN name are
potentially also affected, must be deemed another colossal Institutional
failure from ICANN, that will doubt result in endless litigation.


I know you under huge pressure now in terms of time, but this issue has
already dragged on for a decade and despite delayed deadlines and
undertaking to ensure you get things right there is no clarity on key
issues that affect the security and stability of the Internet.


Now, is not only the time to do it, but it is time to do it right. And I
entirely disagree with the Verisign approach to close the door on
possibility of correcting problems that they have dragged their feet on
resolving at this juncture. If they want to have closure, then it time
for them to stop ducking the issues and step up to the mark and do the
right thing now. ICANN must be seen to be protecting the one group whose
interest it should have been Championing all along and that is the much
neglected domain Registrants.


So I have no problem in principal with this document, but see it only as
basis for a tighter contractual framework that extends well beyond its
scope, particular for IDN domains, where there are so many lose ends
regarding Transliterated IDN versions of existing gTLDs.



Best Regards


Dave Wrixon BSc (Hons) DMS CEng MICE MIStruct E

Contracts Manager

Structures Asset Management




Openness - Collaboration - Mutual Dependency - Professional Delivery 
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