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Comment on IDN Variant TLD Program -- Draft Final Report
- To: "comments-variant-ux-18jan13@xxxxxxxxx" <comments-variant-ux-18jan13@xxxxxxxxx>
- Subject: Comment on IDN Variant TLD Program -- Draft Final Report
- From: Kal Feher <Kal.Feher@xxxxxxxxxxxxxxx>
- Date: Sat, 2 Mar 2013 10:09:30 +1100
To the authors of the report,
I would like to make the following comment on Recommendation 6 within the
report:
Requiring registries to implement the same LGRs as those used in the root, for
their relevant script, is onerous technically and not justified by any
reasoning within the report.
While the use of common LGRs is advantageous to the consumers (and those that
write software for them) of IDN domain names, this advantage is already well
understood by registries who have deployed IDNs. There is no discussion within
the paper as to why, when faced with these advantages, some registries have
opted not to use the same LGRs, while others have chosen to use LGRs already
implemented.
If the option of voluntarily using the same LGR exists, as it does today, then
there should be a strong reason to require through additional regulation that
TLDs use common LGRs. Such a reason has not been put forward in the report. As
a result, this appears to be excessive regulation that may stifle innovation in
the IDN market for no clear benefit. Today an open market exists and TLDs are
free to choose to use common LGRs, with the benefits such commonality delivers,
or not to do so. There is no discussion as to how the market's current
cooperative approach has failed and how further regulation would assist.
To put it another way, while it may well be acknowledged that developing an
alternate LGR by an IDN TLD is likely to cause them to be less successful (from
an accessibility and perhaps popularity point of view), regulations should not
be used to prevent such an occurrence.
I suggest that recommendation 6 have the word "require" replaced with
"request". Full suggested recommendation:
ICANN should request IDN TLD registries with variants to apply the relevant
(script) subset of the root zone LGR and state life cycle for variants across
second-level domain labels. Deviations should be justified.
Kal Feher
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