APTLD's Comment on the IDNC WG Final Report

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

Dear Sir/Madam,

 

APTLD would like to take this opportunity to thank the IDNC Working Group
for their hard work and dedication in producing a methodology for the Fast
Track.  We would like to provide the following comments on the Final Report
for your consideration.

 

1.     The technical reference "Technical Reference Manual for the
standardization of Geographical Names", referenced in the IDNC WG Final
Report, does not include some countries or economies which are already in
the ISO 3166-1 list and in the IANA database. (e.g. the "PALESTINIAN
TERRITORY, OCCUPIED (.ps)").  It is worth emphasizing that such situation
does NOT disqualify those countries or economies from joining the Fast
Track, because the master reference is the ISO 3166-1 list only.  Also, it
is worth reiterating that the stated technical reference is only one of the
three possible sources for demonstrating whether the language for the chosen
IDN ccTLD is indeed the Official Language.

 

2.     On page 7 of IDNC WG Board Proposal, the last but three paragraph
says

 

"A language is demonstrated to be an Official Language:

a. ... 

b. If the language is listed as an administrative language for the relevant
Territory in ISO 3166-1 standard under column 9 or 10; or c. If the relevant
public authority in the Territory confirms that the language is used in
official communications of the relevant public authority and serves as a
language of administration."

 

A specification of which ISO 3166-1 standard under column 9 or 10 is being
referred to would be useful.

 

3.     The delegation process for new IDN ccTLDs should not be used to
"force" ccTLDs to enter into contractual agreements with ICANN.  In many
cases, a ccTLD represents sovereignty or a territorial/national right and
cannot be subjected to a contract with a corporation under the laws of
another country.  Also, for certain countries/territories, the laws of the
affected country/territory or the United States may not allow the signing of
a contract that involves the rendering of services by a US entity.  For
these and other reasons, instead of a uniform format of agreement between
ICANN and the affected country/territory, an exchange of letters not
violating laws of respective countries should suffice.  Otherwise, this will
involve a very heavy and slow governmental process that will introduce
significant delay to the implementation.

 

4.     In Section 2.2、Bullet No.9 says

 

"It is demonstrated that the selected string in combination with the
language/script table when being used, in for example e-mail addressees,
URIs etc, does not create any rendering or other operational issues."

 

However, it is not clear how demonstration of "creating no rendering or
other operational issues" can be achieved.  The following should be
clarified in the coming staff report on implementation.

- What "does not creating rendering or other operational issues" means, and 

- how it can be demonstrated.

 

 

 

Best regards,
Jonathan Shea
Chairman, APTLD

CEO of HKIRC / HKDNR
Ph: +852 2319 3821
Fax: +852 2319 0626

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