Public Comment – Initial Report on the Translation and Transliteration of Contact Information Policy Development Process
ARI Registry Services (ARI) thank the members of the working group for their ongoing efforts and welcome the opportunity to comment in this forum. ARI supports a linguistically diverse and inclusive internet and encourages balancing the local needs of domain registrants with the global needs of internet participants and law enforcement. However, we do not consider that mandatory translation and transliteration of contact information into a single common language (English) or script (ASCII) (“transformation”) will advance these goals. We support the arguments opposing mandatory transformation as made by the PDP and, in respect of the particular recommendations; we actively support recommendation #1 against mandatory transformation of contact information and recommendation #2 in favour of a Registration Directory Service (RDS) that supports non-Latin script inputs. In submitting this comment, we referred to the PDP’s Charter and acknowledge its recognition of other working groups, studies and reports addressing the difficulties posed by the current WHOIS system. We particularly note the Expert Working Group on gTLD Directory Services, the final report of which recommended a complete overhaul of the current WHOIS system and the implementation of a “next generation Registration Directory Service”. We understand that the RDS Work Plan is in development and that 2015 will see the establishment of various new PDPs in this space. We further refer to the advisory clarifying WHOIS obligations published in September 2014 and the various other groups, including the Privacy and Proxy Services Accreditation Issues Working Group and the WHOIS Accuracy Pilot Study Report. We also acknowledge that the PDP’s recommendations are likely to help shape the future development of any new RDS. In light of the numerous separate efforts taking place, and the associated complexities experienced by stakeholder groups in understanding the WHOIS space and keeping up to date, we would encourage ICANN and the wider community to take a step back and adopt a broad perspective. We submit that community stakeholders need an opportunity to understand how the recommendations of the PDP will contribute both towards operations in the short term and towards the WHOIS of the future. Without clear oversight, we fear that short term policy developments, and their associated expenditure, will fail to result in the effective accomplishment of long term goals. Conclusion We support the PDP’s recommendation against mandatory transformation of contact information and the development of an RDS that supports non-Latin script inputs. However, in respect of the other recommendations, we also seek to highlight the difficulty in understanding how the recommendations fit into the broader WHOIS framework and encourage further community discussion leading to the development of a Registration Data Directory Service that will support the future of the internet. Regards, Donna DONNA AUSTIN Policy and Industry Affairs Manager ARI REGISTRY SERVICES Melbourne | Los Angeles P +1 310 890 9655 P +61 3 9866 3710 E donna.austin@xxxxxxxxxxxxxxx W www.ariservices.com Follow us on Twitter The information contained in this communication is intended for the named recipients only. It is subject to copyright and may contain legally privileged and confidential information and if you are not an intended recipient you must not use, copy, distribute or take any action in reliance on it. If you have received this communication in error, please delete all copies from your system and notify us immediately.