Comments from Association UNINET

[Iliya Bazlyankov <iliya.bazlyankov@xxxxxxxxx>]

Dear All,

The Bulgarian Association UNINET fully and unconditionally supports the 
creation of an objection/re-evaluation mechanism for declined IDN ccTLD 
requests in the Fast Track process.
The reasoning behind this is the outcome of the Bulgarian IDN ccTLD Fast 
Track request. Our association was the first group in Bulgaria that 
started public discussions about an IDN ccTLD back in 2006. During all 
these years (2006-2010), we conducted many polls and surveys, and all of 
them had the same result – Bulgarian Internet community would accept 
only the .бг (IDN .bg) string and would vote against any other proposal.
We were very surprised to hear that in May 2010, the DNS Stability panel 
has declined the Bulgarian proposal for an IDN ccTLD string. During the 
ICANN meeting in Brussels, we read the Stability panel`s decision and 
had numerous remarks and objections; however, we were unable to contact 
officially anyone from the panel, due to the anonymous nature of the 
process. Also, there isn`t any procedure to object the decisions in the 
Fast track.
Since we were unable to do anything to clarify the situation, I believe 
the best possible option for Bulgaria would be to be able to apply for a 
re-evaluation in a modified fast-track process. This time the evaluation 
has to be more open, so all interested parties would be able to submit 
comments and proposals.
Two ideas are being actively discussed in Bulgaria – the first is the 
obvious one – that the Bulgarian IDN ccTLD must contain only Cyrillic 
characters, from the official Bulgarian alphabet. The second one is to 
limit the characters that could be used in a domain name registration – 
each domain must contain a letter that is visually different to the 
Latin script – they have to be one of  “б, г, д, ж, и, й, л, п, ф, ц, ч, 
ш, щ, ъ, ь, ю, я”. Both ideas can be put in the contract between ICANN 
and the prospective IDN ccTLD operator.
Therefore, we urge the ICANN board to approve the modification of the 
fast-track procedure and allow requests for re-evaluation with more 
supporting documents to be sent from rejected countries like Bulgaria.
--
Kind regards,
Iliya Bazlyankov

Chairman of Association UNINET

http://www.uninet.bg
iliya.bazlyankov@xxxxxxxxx

Phone: +359 2 416 34 88, +359 2 492 3881
Mobile: +359 87 903 76 15
Fax: +359 2 80 43 111