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CDNC concerns on IDN policy requirement on New gTLD draft guideline

  • To: <gtld-guide@xxxxxxxxx>, <gtld-evaluation@xxxxxxxxx>
  • Subject: CDNC concerns on IDN policy requirement on New gTLD draft guideline
  • From: "YAO Jiankang" <yaojk@xxxxxxxx>
  • Date: Thu, 27 Nov 2008 00:48:31 +0800

CDNC concerns on IDN policy requirement 

on New gTLD draft guideline

 

Chinese Domain Name Consortium (CDNC, http://www.cdnc.org) welcomes the 
publishing of the draft "New gTLD Applicant Guidebook" (the Guidebook) by ICANN 
for public comment. CDNC believes that the Guidebook demonstrates good 
advancement towards IDN gTLDs and congratulates ICANN on the progress. However, 
CDNC would like to express a significant concern regarding Section 2.1.1.3.2 
String Requirement (Module 2, page 2-7) in the Guidebook, which said:”Policy 
Requirements for Generic Top-Level Domains – Applied-for strings must be 
composed of three or more visually distinct letters or characters in the 
script, as appropriate”, where a limitation on the minimum number of characters 
for an IDN TLD string is introduced.

In the case of Chinese IDN TLDs, the limitation to 3 or more Chinese characters 
would be a substantial deterrent for the adoption of Chinese IDNs. Most Chinese 
words are composed of 2 Chinese characters. And if such limitation is set on 
Chinese strings, it is impossible to form a meaningful 3-character string in 
Chinese. Also, the limitation on number of characters in the IDN TLD string 
does not represent the interest of the community that CDNC serves, and will 
create significant impact on stakeholders in IDN business and user communities 
as a whole.  From our experience with IDNs, our participation throughout the 
technical standards development process at IETF, policy discussions at GNSO on 
this topic, as well as at the IDNC Fast-Track IDN ccTLD discussions, there is 
no indication of any reason to limit the minimum number of characters 
applicable for Chinese IDN TLDs.

We refer to the GNSO Final Report suggesting that: Single and two-character 
U-labels on the top level and second level of a domain name should not be 
restricted in general. At the top level, requested strings should be analyzed 
on a case-by-case basis in the new gTLD process depending on the script and 
language used in order to determine whether the string should be granted for 
allocation in the DNS.

Hence, CDNC suggests removing or modifying the following paragraph in Module 2, 
section 2.1.1.3.2 page 2-7 of the guidebook to meet the special situation for 
the Chinese language: Policy Requirements for Generic Top-Level Domains – 
Applied-for strings must be composed of three or more visually distinct letters 
or characters in the script, as appropriate.

CDNC respectfully urges ICANN and ICANN staff to consider the suggestion by 
CDNC and to uphold the policy recommendation on this regard by the GNSO, taking 
into account the interests of our community.

 

 

Chinese Domain Name Consortium

November 27, 2008

Attachment: cdnc-idn-new-gtld-comments.pdf
Description: Adobe PDF document



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