Cost of Transliteration from ASCII to IDNs

["Ron Andruff" <randruff@xxxxxxxxxxxxxxx>]

Transliteration of Strings from ASCII to Other Scripts (not referenced in
the Applicant Guidebook)

 

The notion that every ?label?, or applied for string, should cost an
applicant USD 185,000 is incongruous with ICANN?s contention that the fee
has been established to ensure application costs for new TLD review (past
and present) are covered.

 

Should an applicant pass all RFP criteria and move to contract with ICANN to
manage a TLD on behalf of a particular community, charging that same
applicant an additional USD 185,000 for EACH additional transliteration of
that same string into Cyrillic, Kanji, or Arabic character sets is
unconscionable.  How much could it possibly cost to have a single word in
different character sets or languages reviewed?  I would propose that even
USD 5,000 would be an exorbitant amount ? but to require an additional USD
180,000 on top of that has zero basis and serves no other entity other than
ICANN itself.

 

Furthermore: 

 

3.1 One could well argue that allowing a second entity to apply for and
secure the right to manage a transliteration of the same TLD string in
another character set contravenes the ?confusingly similar? aspect of the
RFP.  Many people in the world are multi-lingual and for them switching
languages with equally linguistic colleagues, from English to German to
Arabic in the same conversation is normal.  The same word in multiple
language sets means the same thing to them. There is no distinction.
Neither should there be for applicants.  

 

Should ICANN not address this aspect correctly, i.e., add a section to the
RFP that would allow for applicants to apply for their intended strings in
multiple character sets (which also greatly supports ICANN?s IDN efforts) ?
each with an additional review fee for each character set or language ? then
ICANN will be forcing TLD applicants to spend inordinate financial and human
resources on challenge processes that they should otherwise never have
reason to engage in.  Both the money and the time would be much better spent
on development of their TLD on behalf of their global communities. 

 

      3.2 One of ICANN?s oft-stated key responsibilities is the stability
and integrity of the Internet.  Yet, should ICANN allow two or more
registries to manage what is effectively the same TLD (albeit in a different
IDN character sets or translated into different languages), it would become
a willing party to the disastrous potential for resolution collisions, lost
traffic and other user issues.  Maintaining the stability and integrity of
the Net, in this case, means that one registry operator alone should ? if
that registry so chooses ? be the manager of that string irrespective of the
number of languages or character sets it may be available in.  Giving this
option to new TLD applicants is simply good ICANN management of the DNS.
Existing registries would need to go through the same application process as
new, would-be entrants, however in this case incumbents would need to apply
for one transliterated or translated name for the TLD they already manage,
along with any others they wish to manage.  In this way, every TLD applicant
and current registry will be treated equally.

 

3.3 Allowing a winning registry to have authority over their ASCII and IDN
equivalent TLDs, i.e., all applied for ASCII and equivalent transliterated
and/or translated names (with the appropriate fees attached), would enable
registries to offer their registrants a package, a combination of ASCII and
IDN names, to fulfill the registrant?s needs (without concern about
collisions or lost traffic issues).  The point of the entire exercise in
rolling out new TLDs is to provide users more choice.  Allowing new
registries to better manage new name spaces on behalf of their communities
by offering registrants multiple options vis-à-vis languages or IDN names is
the logical and technically sound way forward in the expansion of the name
space.

 

Sincerely,

 

Ronald N. Andruff

 

 

 

RNA Partners, Inc.

220 Fifth Avenue, 20th floor

New York, New York 10001

 

www.rnapartners.com 

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