fast track .бг - too fast, please stop and think

[Ludmil Minkov <lminkov@xxxxxxxxx>]

Dear ICANN,

The IDN domains were introduced in order to make the internet a place
where all people in the world will feel home there. Where they can
recognise their ethnical and national identity. This is a wonderful
initiative. But the rejection of .бг is totally contrary to what ICANN
was saying and so proud of.

1. The domain .бг is for the Bulgarian people. All people in Bulgaria
know that .бг stands for Bulgaria. It is natural, it is what it is.
Any other alternative would mean forcing millions of people to act in
contradiction to their national identity. This is not why ICANN
introduced the IDN, why they put so much effort in this process.

2. ICANN says that .бг looks similar to .br. This is certainly and
absolutely not the case. Bulgarian people know the difference between
"б" en "b" also the difference between "б" en "6". I'm sure Brazilian
people can see this difference as well. When Bulgarian people learn
latin letters, they are never thought that they should write the latin
"b" as a cyrilic "б". Nor the latin "r" as a cyrilic "г". Rather they
say that the hand written "r" can be written as the cyrilic "ч". Same
for people learning Bulgarian, no one will teach them to write the "б"
like a "b" or the "г" like a "r". I believe an more in depth study and
understanding of the Cyrilic script will help ICANN to see the big
difference between these 4 charachters.

3. Even if there would be some similarity between "бг" en "br", the
first part of the domains would be written fully in Cyrillic. No
Brazilian domain will be written in Cyrillic.

4. Talking about confusion. Choosing another TLD than ".бг" for
Bulgaria will confuse millions of people, actually all people in
Bulgaria. Many, many more than the number of people who would confuse
".бг" with ".br". Just check the facts, use the Google data and see
the millions of searches where people just type "бг" after every
keyword. No one use any other alternative.
http://adwords.google.com/select/KeywordToolExternal
Or check this other tool:
http://www.google.com/insights/search/#q=%D0%B1%D0%B3%2C%D0%B1%D1%8F%2C%D0%B1%D0%B3%D1%80&geo=BG&cmpt=q

5. ICANN has approved exact the same cases in the past.

Take the Cyrillic character "б" and rotate it 180 degree - then it
becomes the Latin "g" (sort of). Then take the Latin "b" (from .br)
and rotate it 180 degree - it becomes a "q". Meaning that "б" relates
to "b" in the same way like "g" relates to "q". This is very
important. So the question is, is there enough difference between "g"
and "q", are they confusingly similar? According to ICANN the answer
is NO, not at all. The following strings have been already approved,
based only on the difference between the "g" and the "q":

.ag - .aq
.ga - .qa
.gq - .gq
.mg - .mq

If the curl of the "g" is curly enough to make it different than the
straight "q", then the curl of the "б" should be sufficient to make it
different enough from the straight "b". Otherwise all other string
couples mentioned above should be disputed as confusingly similar,
which in my opinion, is not the case.

6. This is not about visual confusion. It's about confusing the hearts
of millions of people when they use internet each day of their lives.
So, please, consider the people and the many generations that will use
the string. This was the purpose of the introduction of IDN in the
first place, to give local people what's in their heart, give respect
to their culture and diversity. I believe strongly that along with
stability, preserving the national and cultural identity should be
both top priorities for ICANN in the IDN process. When denying the .ру
ICANN had no choice, the string was exactly the same with .py. But .бг
vs .br is a different case.

7. In any process there could be errors, also in the Fast Track
Process Review. That's all right. Just make it possible, to recover
from those errors by providing the possibility to apply again or to
appeal.



Best regards,



Ludmil Minkov,

Online Marketing Spacialist