Universal Acceptance Initiative

[Donna Austin <Donna.Austin@xxxxxxxxxxxxxxx>]

ARI Registry Services welcomes the opportunity to comment on ICANN's Universal 
Acceptance Initiative: An Abridged Roadmap.

We support the comments that have been submitted by the APTLD and also offer 
the following comments for consideration.

During London, ICANN and community members discussed how ICANN could best 
implement the Strategy Panel on the Public Responsibility Framework 
recommendations on ICANN's public responsibility and serving the global public 
interest, which the Panel defined as follows:

"As one of the stewards of the Internet, ICANN recognizes it has a 
responsibility to protect and promote the global public interest, both 
throughout its work, and in collaboration with other entities. ICANN's public 
responsibility permeates all areas of its work and is at the core of its 
operations.

ICANN defines the global public interest, in relation to the Internet, as 
ensuring the Internet becomes, and continues to be, stable, inclusive, and 
accessible across the globe so that all may enjoy the benefits of a single and 
open Internet. In addressing its public responsibility, ICANN must build trust 
in the Internet and its governance ecosystem."

It would seem that as the organisation responsible for the introduction of new 
TLDs, including IDN TLDs, ICANN has a global public interest responsibility in 
making sure that what has been claimed as the biggest change to the Internet 
since it began actually works and is accessible to everyone. Universal 
acceptance of all TLDs is critical to the overall success of the new gTLD 
program and ultimate trust in the Internet and as such should this should be a 
high priority for ICANN.

ICANN should be a driving force behind ensuring that registrants have a 
consistent and predictable experience when they use the Internet. Creating a 
sense of urgency is an admirable goal, but it's difficult to understand how 
this will motivate stakeholders to take proper action and what purpose it 
serves without being underpinned by concrete deliverables. The roadmap is heavy 
on rhetoric and light on detail: it is significantly focussed on raising 
awareness of the problems and sharing information whereas a considerable focus 
should be on finding solutions. The roadmap should include targets, timeframes 
and concrete examples. How will ICANN be educational and pro-active-what's the 
target audience, what's the reach, what's the message. How will promoting 
internationalised email as a way to enable full functionality of IDN TLDs 
actually overcome the fact that IDN based email is almost non-existent-what 
will ICANN do in order to remedy this problem?

More concrete steps towards resolving the problem could include undertaking IDN 
research and analysis in order to better understand the problem and share this 
with stakeholders with a view to finding solutions. ICANN could provide funding 
(or research grants) for university and private sector development of services 
that use IDNs. 

Rather than providing another roadmap, we believe that a plan that clearly 
identifies the what, how, who and when would be a better tool for focussing 
activities and striving towards deliverables that lead to Universal Acceptance 
of all TLDS-which should be the ultimate aim of the plan.

Regards,

Donna

DONNA AUSTIN
Policy and Industry Affairs Officer

ARI REGISTRY SERVICES
Melbourne | Los Angeles 
P  +1 310 890 9655
P  +61 3 9866 3710
E  donna.austin@xxxxxxxxxxxxxxx
W  www.ariservices.com

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