Comments from APTLD on the Draft IDN ccTLD Fast Track Implementation Plan

["Jonathan Shea" <jonathan.shea@xxxxxxxx>]

Dear Sir/Madam,

 

APTLD would like provide the following comments on the Draft IDN ccTLD Fast
Track Implementation Plan.

 

I.      APTLD Overarching Position

 

APTLD sees the delegation of IDN ccTLDs in the same light as existing ccTLDs
– they are for the local communities to operate for their own communities
use – the only significant difference is that the IDN ccTLD finally
provides a facility for people to completely use the Internet in their own
language or script.  Otherwise, we see no change in the status quo
relationship from the existing ccTLDs.

 

II.      The Draft IDN ccTLD Fast Track Implementation Plan raises the
following additional topics for discussion.

 

1)      Relationship between ICANN and the IDN ccTLD Operator

a.  A voluntary, documented relationship is available between the IDN ccTLD
Operator and ICANN – just as it is available to existing ccTLDs.  This
could take the form of a contract, an accountability framework, an exchange
of letters or some other vehicle deemed appropriate by ICANN and the ccTLD
Manager.

b.  For those operators who, for whatever reason, do not want to exchange
documents with ICANN, a commitment to the stability and security of the
Internet, including compliance with the IDNA Guidelines and Protocols,
should be sufficient.

2)      Financial Contributions

a.  As indicated above, we see no difference between the existing ccTLDs and
the new IDN ccTLDs.

b.  The operators of the new IDN ccTLDs can make a voluntary contribution or
enter into a more structured mechanism for financial contributions to
support ICANN and its work.

3)      Relationship with the ccNSO

a.  We support the recommendation that new IDN ccTLD operators be given the
opportunity to actively participate in the ccNSO and that the ccNSO, as part
of its extensive Policy Development Process on IDN ccTLDs, should actively
consider methods to include the IDN ccTLD operators into the ccNSO
structure..

4)      Contention Issues with the new gNSO process

a.  The new gNSO process includes a provision for objection.

b.  We also note the previous recommendation from both the GAC and the ccNSO
that new gTLDs should NOT represent the names of countries or territories
listed in the ISO 3166 list.  We continue to support this.

c.  We continue to support the rights of nations and territories to use the
Internet to establish their own ‘space’ on the Internet.

d.  We also recognise ICANN’s unique position in coordinating a stable and
secure and interoperable single network.  Toward that end, avoidance of
confusion is necessary.  

e.  Should contention arise during the Fast Track IDN ccTLD implementation,
then facilitation of discussion should occur, and failing resolution, then
no progress should occur until the PDP process is complete.

5)      Evaluation

a.  We support the staff’s recommendation and hope that the full PDP
proceeds with sufficient urgency that no more than one review of the Fast
Track IDN ccTLD application will be required.

6)      IDN Table

a.  To maintain consistency with the ICANN IDN Guidelines, an IDN Table
already adopted by a ccTLD registry for its second-level IDN implementation
should be used for its top-level IDN ccTLD implementation.

7)      Technical Committee and Supporting Documents

a.  Our members would like to have more details regarding the formation of
the Technical Committee and the documentation to be provided, as well as the
String Confirmation Process. For instance, the selection criteria for
nominating and appointing members to the Committee, definition and format of
the supporting documents required, the process of verifying the
documentation submitted by the requestor and the time allocated to each
stage of the process have to be specified.

 

 

Best regards,
Jonathan Shea
Chairman, APTLD and

Chief Executive Officer, HKIRC
Ph: +852 2319 3821
Fax: +852 2319 0626

 

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