Comment on IDN Variant TLD Program -- Draft Final Report

[Kal Feher <Kal.Feher@xxxxxxxxxxxxxxx>]

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