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Translation / Transliteration Comment from Blacknight

  • To: "comments-transliteration-contact-initial-16dec14@xxxxxxxxx" <comments-transliteration-contact-initial-16dec14@xxxxxxxxx>
  • Subject: Translation / Transliteration Comment from Blacknight
  • From: Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>
  • Date: Sat, 17 Jan 2015 19:22:44 +0000

Dear Sir / Madam

I am submitting these comments in my capacity as CEO and Founder of Blacknight 
Internet Solutions Ltd, an ICANN accredited registrar based in Ireland.

Firstly I would like to thank the members of the Working Group for their 
efforts to tackle this matter. Volunteer work is at the core of ICANN's 
activities and should be recognized and appreciated.

With respect to the matter at hand.

We are an Irish company and the majority of our clients are Irish. 
Under Article 8 of Bunreacht na hÉireann (the Irish constitution) Ireland 
recognises both the Irish language and the English language:


1 The Irish language as the national language is the first official language.

2 The English language is recognised as a second official language.

3 Provision may, however, be made by law for the exclusive use of either of the 
said languages for any one or more official purposes, either throughout the 
State or in any part thereof."

What this means is that many Irish people use the Irish language version of 
both their names and their addresses in everyday life. This is their right. In 
fact we have a portion of our clientele who will attempt to communicate with us 
primarily via the Irish language.

For ICANN, or any entity associated with ICANN, to suggest that it is going to 
oblige registries, registrars and registrants  to translate or transliterate 
placenames and people's names to another language (English) is, for lack of a 
better word, nuts.  To even attempt to do so is offensive. 

For registrars, registries and registrants any such move would add an increased 
cost burden - assuming that it was even feasible to do it. Personally I don't 
think you can do it.

How do you differentiate between a name that can be translated and one that 

Take the name "Seán" - is it "John" or "Shane"? The correct answer is neither - 
it's Seán. 

My first name is Italian. It's not English. It might be "easier" for some 
people to anglicize my first name, but any name they use that is not my first 
name is never going to be accurate or correct.

Is mise le meas,


Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Domains
Intl. +353 (0) 59  9183072
Social: http://mneylon.social
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland  Company No.: 370845

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