dotShabaka Registry Comments – Initial Report on the Translation and Transliteration of Contact Information Policy Development Process

["Yasmin Omer (DotShabaka)" <yasmin.omer@xxxxxxxxxxxxxx>]

International Domain Registry Pty Ltd trading as dotShabaka Registry (hereafter 
referred to as “dotShabaka Registry”) – Registry Operator for شبكة . –  Public 
Comment – Initial Report on the Translation and Transliteration of Contact 
Information Policy Development Process

We thank the working group for its ongoing efforts and welcome the opportunity 
to comment on the initial report.

dotShabaka Registry trades as the registry operator for the Arabic new generic 
top level domain (“gTLD”) شبكة. The شبكة . gTLD, which represents the most 
common term for internet in Arabic, launched in October 2013 and is targeted at 
Arabic language speakers.
dotShabaka Registry supports the PDP’s recommendation against mandatory 
transformation of contact information. We agree that mandatory transformation 
would result in significant detriment to the continuing efforts of ICANN and 
the wider community to create a linguistically diverse internet and would 
disproportionately burden small players and underserved regions. These 
detriments far outweigh perceived benefits. Further, in light of the nature of 
the initial report, being only one in a cohort of many groups, studies and 
efforts relating to the WHOIS system, we seek to highlight the difficulty in 
understanding how the recommendations fit into the broader WHOIS framework and 
encourage further community discussions.

Creating an internationally inclusive internet
dotShabaka Registry’s mission is to empower the Arabic language on the 
internet. Paramount to achieving this mission is offering registrants and 
internet users an end-to-end Arabic experience, including an Arabic domain name 
registration interface. We therefore find it disappointing that WHOIS remains 
the sole feature of the domain name registration experience that requires 
registrants to have knowledge of the English language and ASCII script. There 
are over 380 million Arabic language speakers throughout the world and we find 
the notion that Arabic (and other non-English/ASCII) domain name registrants 
would be mandated to have their contact information transformed unacceptable.
A 2013 study found that the IDN market had experienced 215% growth in the past 
five years and constituted 2% of the worlds’ domain names.[1] This report was 
based on a total of 26 country and territory IDNs and only 2 IDN gTLDs. There 
are now 70 IDN gTLDs[2] and significant growth in this market is anticipated. 
We support the PDP’s findings that some international registrants may be unable 
to enter their contact information in English or ASCII and submit that 
mandatory transformation may result in a further barrier to entry to 
registrants and registrars in underserved and less developed regions. We 
therefore support the PDP’s recommendation that any new Registration Data 
Directory Service (“RDDS”) contemplated by ICANN be capable of receiving input 
in the form of non-Latin script contact information.

Current WHOIS efforts
We note that whilst we actively support recommendations #1 and #2, in respect 
of recommendations #3 to #6, we advocate further community discussions to 
increase the understanding of how the PDP’s recommendations, and the efforts of 
other WHOIS related groups, will fit together and eventually create a new RDDS. 
We particularly refer to the recommendations of the Expert Working Group on 
gTLD Directory Services and the roll out plan currently being developed. We 
fear that the multitude of disjointed efforts could result in the short term 
implementation of costly recommendations without the associated benefits of a 
long term plan for a sustainable RDDS.

Conclusion
We recognise the difficult task faced by the PDP in developing recommendations 
in a fast changing policy space. We reiterate that as the internet becomes more 
linguistically diverse, we encourage ICANN and the wider internet community to 
cooperate in seeking to achieve a truly internationalised internet, a concept 
which we do not believe can occur under mandatory transformation of WHOIS 
contact information.
We again thank the PDP WG for the opportunity to comment on the report and look 
forward to discussing these issues further at the upcoming ICANN 52 meeting in 
Singapore.

Regards,

Yasmin Omer




________________________________

[1] euID report published August 2014 and available 
here<http://www.eurid.eu/files/publ/IDNWorldReport2014_Interactive.pdf>.

[2] The number of gTLDs with signed Registry Agreements as at 23 January 2015.