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Comments from Association UNINET

  • To: fast-track-review-2010@xxxxxxxxx
  • Subject: Comments from Association UNINET
  • From: Iliya Bazlyankov <iliya.bazlyankov@xxxxxxxxx>
  • Date: Wed, 15 Dec 2010 09:49:35 +0200

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


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