Public Comment – Initial Report on the Translation and Transliteration of Contact Information Policy Development Process

[Donna Austin <Donna.Austin@xxxxxxxxxxxxxxx>]

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

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