EURid Comments on Draft Recommendations Overall Policy for the Selection of IDN ccTLD Strings

[Chhun Chy <chhun.chy@xxxxxxxxx>]

EURid Comments on Draft Recommendations Overall Policy for the Selection of IDN 
ccTLD Strings

Submitted by ICANN staff on behalf of EURid

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EURid, the registry manager for the .eu top level domain, would like to thank 
you for the opportunity to comment on the Draft Recommendations Overall Policy 
for the Selection of IDN ccTLD Strings and for having been invited to 
participate in the discussion of the working group.

We respectfully submit the following input to your attention. Our feedback is 
based on our experience with the Fast Track procedures and the expertise we 
have gained in the IDN environment.

Firstly, we would like to support two of the overarching principles at the 
basis of this exercise: more precisely, the principles of preserving the 
security, stability and interoperability of DNS and of ensuring that the 
request for delegation of an IDN ccTLD should be an ongoing process.

Concerning the confusingly similarity of IDN ccTLD Strings, we appreciate that 
the recommendations address the challenged element of the possible similarity 
with gTLD applications and therefore, we fully support that any confusing 
similarity should be investigated against "any combination of ISO 646 Basic 
Version characters and existing TLDs and reserved names". This will facilitate 
the possibility for worldwide communities to express themselves in their own 
language at the top level without being prevented to do so by TLD applications 
that are not yet approved by the ICANN Board.

As for the String Validation Stage, we welcome the introduction of both the 
Similarity Review Panel and the Extended Similarity Review Panel. We are also 
happy to see that it is recommended that names of the panellists are made 
public in the spirit of ensuring transparency to a process that so far 
distinguished itself for several obscure aspects. We suggest that the two 
aforementioned panels are made of experts with sound scientific and academic 
records as for language studies and character perception.

Last but not least, we exhort ICANN staff involved in the validation process to 
set precise timeframes for the various validation steps to be performed and 
completed so that any requester can adequately report back to the language 
community(ies) that is behind any application.

We thank you once more for the opportunity to comment and participate in the 
process.

Giovanni Seppia
External Relations Manager

EURid
Woluwelaan 150
1831 Diegem - Belgium
TEL: +32 (0) 2 401 2750
MOB:+39 335 8141733
giovanni.seppia@xxxxxxxx
http://www.eurid.eu
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The European Registry of Internet Domain Names