JPRS comments on Guidelines for Developing Reference Label Generation Rulesets (LGRs) for the Second Level

[hotta@xxxxxxxxxx]

Dear ICANN,

Please see the JPRS comments on Guidelines for Developing Reference
Label Generation Rulesets (LGRs) for the Second Level as follows.


Comment#1: If additional Contextual Rules are required by ICANN, 
           they must be described clearly

  In our experience as one of new gTLD registries, we were requested 
  to add additional Contextual Rules for U+3006 (IDEOGRAPHIC CLOSING 
  MARK) and U+30FC (KATAKANA-HIRAGANA PROLONGED SOUND MARK) by PDT 
  provider (*).  Those characters are PVALID in IDNA2008 and no 
  additional Contextual Rules do not exist in IDN standard.  If ICANN 
  requests such Contextual Rules in addition to the standard, they 
  must be described clearly in the Guideline.  Otherwise, developed 
  reference of LGR will contain different definitions from those 
  implemented in PDT.

  (*) U+3006 and U+30FC are classified as "Common" in Unicode's 
      Scripts.txt, so they seemed not considered as pure Japanese 
      characters.  But those characters are usually used as one of 
      the Japanese characters. We don't know the exact background of 
      the current Unicode specifications.


Comment#2: Consistency of variants in multiple language LGRs that 
           share the same script(s)

  Some of new gTLDs and ccTLDs accept multiple language SLDs.  Such 
  gTLDs/ccTLDs provide multiple SLD LGRs - each for one language- 
  within one TLD.  As well as RootLGR, if some LGRs share the same 
  script(s) and if they have variants, the definition of variants in 
  LGRs must be consistent (*).  This consistency requirements of 
  variants definition in multiple LGRs in one TLD must be described 
  clearly in the Guideline.

  (*) Chinese/Japanese/Korean coordination work for Han script is 
      ongoing in RootLGR Project.


Comment#3: Consistency with IDN rules defined for existing TLDs

  We understand that projected SLD LGR won't be specifically targeted 
  to ccTLDs and existing gTLDs.  In addition to that, we also 
  understand that the the purpose of the SLD LGR definition is to 
  facilitate coherent user experience.  Considering these, we hope 
  the projected IDN rules to be the same or to incorporate the basics 
  of rules for existing gTLDs and ccTLDs as many IDNs have been and 
  are already accepted and used globally. 

Regards,
Hiro Hotta
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Japan Registry Services Co., Ltd.(JPRS)
Tel: +81-3-5215-8451
URI: http://jprs.co.jp/en/
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