CDNC comments to LGR second level

[王伟 <wangwei@xxxxxxx>]

As an independent non-profit organization, CDNC is committed to the 
coordination and regulation about Chinese domain name around the world.
Since early 2000s, CDNC has generated its IDN table and registration rule which 
have been applied to .CN, .TW, .HK. .SG , dozens of new gTLDs, and etc.


Though CDNC realizes that there remains many other Chinese script TLDs whose 
table and generation rule are different from CDNC’s practice, and holds the 
view that a unified table and rule for the second level might help to provide 
the unified experience for global end users, the timing might not be good.

We don’t see much necessity to formulate the Label Generation Rulesets (LGRs) 
for all second level domains at THIS TIME.
We don't believe the differences in characters, variant, contextual rules, and 
format constitute a problem that ICANN could address before the root label 
generation rule is finalized.

Moreover, it will be unfeasible to deal with the issue at the second level 
before a consensus on registration policy is reached among IDN TLDs.