Comments by Chinese Domain Name Users Alliance

[Hong Xue <hongxueipr@xxxxxxxxx>]

a) Fast-track IDN ccTLDs must be implemented as planned, i.e. in Q4 of 2009
as the latest, to meet the "pressing need" of non-ASCII user community;

b) Any implementation plan must strictly observe the IDN Guidelines and IDN
tables reserved at the ICANN. Any ignorance on variant character set would
cause serious user confusion. The present draft policy on variants would
seriously pledge the non-ASCII users, particularly in Chinese and Japanese
community, by distorting their character usage. If the present policy equals
ASCII TLD variants in either capital letters or low-case letters, non-ASCII
users should have the equal right to use the variant scripts in the relevant
fast-track IDN ccTLDs.

c) The cost estimated for the processing of each new IDN ccTLD request is
prohibitively high. The financial barrier for IDN ccTLD managers especially
from developing countries would widen the digital divide and be against the
ICANN's social responsibility.

-- 
Hong Xue, Ph.D.
Professor of Law
Director of Institute for the Internet Policy & Law
Beijing Normal University
19 Xin Jie Kou Wai Street
Beijing 100875 China