CNNIC comments on string-character limitation

["Tan Yaling" <tanyaling@xxxxxxxx>]

ICANN has put forward a serial of documents and excerpts of the Draft
Application Guidebook. CNNIC would like to make comments on Discussions
about the 3-character String Requirement:

1. Fairness of Treatment
It says in the document that" In addition to comments received from the CJK
community, ICANN received arguments from the European region that certain
single or two character combinations . are allowed for CJK based languages
then they should also be allowed for other languages, for fairness of
treatment."

Fair treatment is needed, but in our opinion the fairness of treatment is to
enable every person on the globe to have access to the Internet, regardless
of its race or language.  Given the dominance of ASCII character on the
Internet in the years, it is high time to give the fairness treatment to
IDNs. This, in our opinion is the right "fairness of treatment" model.

2. on Statements concerning the Chinese words and number of characters 
The document also says that "Other arguments state that few Chinese
characters are words, most Chinese words are two or more characters." 
This statement appears to be a misnomer.  Each single Chinese character is a
word, and in some cases can possess multiple meanings.  The presence of a
2nd character is then used to clarify this meaning.  In fact, it is very
hard to find a 3 character word in Chinese; this usually exists as
"borrowed" words (i.e. translated phonetic pronunciation of an English
term).
The reason we raise this issue is because in the East Asian language
community , it is agreed that 3-characters limitation will excludes most
meaningful words as a TLD string, that why we bring this issue to ICANN
again and again and again to appeal for the lift of this limitation.

Regards

Tan Yaling
CNNIC