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Introduction of IDN ccTLDs - Important Suggestions for Policy preparation of FastTrack

  • To: idn-cctld-issues@xxxxxxxxx
  • Subject: Introduction of IDN ccTLDs - Important Suggestions for Policy preparation of FastTrack
  • From: Imran Ahmed Shah <ias_pk@xxxxxxxxx>
  • Date: Fri, 22 Feb 2008 06:00:55 -0800 (PST)

22 February 2008
Lahore, Pakistan
Important Suggestions for Policy preparation of FastTrack
Introduction of IDN ccTLDs 
Dear M/s cNSO & ICANN

Thank you for providing International Community members to participate for 
Policy making for Introduction of Internationalized Domain Name and to define 

I belong to Asian Internet family & have reservations about the new TLDs .IDN 
and would like to mention some extraordinarily important issues (very briefly) 
to be addressed during the construction of .IDN policies and Project 
Development Process (PDP):

1. Limitations of Naming Convention
2. Limitations of Utility & Usefulness.
3. Proposed Clients for new .IDN ccTLD
4. Proposed Cost of new .IDN ccTLD

1. Limitations of Naming Convention:
With reference to the Naming Convention policy in which is shown as resolved by 
ccNSO at meeting of 2 October 2007 to conclude that either two letter codes 
will be used for ccTLD, in this way ICANN or ccNSO will not be able to 
accommodate all of the regional territories and country codes in International 
Languages (non-English). (Please also see the comments of Dr Sarmad Hussain 
http://forum.icann.org/lists/idn-cctld-issues/msg00014.html) If still there 
English abbreviations have to be used then what is benefit for all of these 
exercises for .IDN TLDs (ccTLD or gTLD). 

Problem Identification: 
It is proposed that basis of selecting 2 letter should be resolved first. 
Now the question arises is that how this modification will be made.
For the reference of UN Authorities they already have abbreviation in 3 letters 
for country codes (please see 
For reference of M/s International Organization of Standardization (ISO), their 
systems and procedures were developed on the basis of traditional English 
abbreviations only to accommodate Internet Community which knows English 
Language. Now the requirement has been changed and demand arisen to develop 
Multilingual Internet to further accommodate 65% non-English Internet Users 
(about 820 million). So if the nonconformity is reported, International 
Organization Standardization has to resolve this issue by deputing their 
resources (support auditors) to develop well-documented nonconformity and 
change their standards to accommodate International Languages for the formation 
of Country and Regional codes of abbreviations. The criteria for the selection 
of abbreviations should be meaningful to adopt with in the community of the 
related Country/ Language. For example Mr Alexey Mykhaylov already pointed 
about the abbreviation of Ukrainian ISO 3166-1 country Code.
 (please see http://forum.icann.org/lists/idn-cctld-issues/msg00009.html)
I can also give you one more example that regarding India and Pakistan, where 
the abbreviations as per ISO 3166-1 country Code list are âinâ and 
âpkâ. Now this should be notices that in their native Language âURDUâ, 
if they use similar policy and used same they will use to speak translated 
characters of following Urdu letters:

1. ØÛÛ ØÛÙ (aka eâie+eân) for âinâ (ÛÙ without space= XN--IHB1Y)
2. ÙÛ ÚÛ (aka pee+keyâ) for pk (ÙÚ without space = XN--3IB0G)

Now if you count the letters of ØÛÛ ØÛÙ  and ÙÛ ÚÛ  these does not 
fit in 2 letters, so using a single character for one-to-one resemblances, one 
can use Û Ù or ØÙ for India and Ù Ú (aka pae+kaff or puk). So there in no 
meaning or easiness in using these abbreviationsâ pattern. 
Please also note that if you continue to adopt two letters pattern in Urdu 
Language/ Unicode/ puny-code character format, the equivalent to XN--IHB1Y or 
XN--3IB0G in English Translation, so these are not only two letters, claiming 
the adoption of ICANN existing bylaws.

I am sure that ISO & UN will be agree to accommodate 820 million userâs 
community and will be ready to modify their lists and abbreviation limitation 
of 2 letters.

Proposed Solution:
It is proposed that the abbreviations for the each Country or Region should be 
defined after then consultation of regional language experts who can understand 
the up and down of the Internet Internationalized Formation.
For the above two countries I can suggest better relevant country codes 
according to the native language of the Asians. And I am quite sure that Dr 
Sarmad Hussain (Expert in Urdu Language) will certify my proposed country code 
abbreviations. If the above problems are justified and ccNSO and ICANN needs to 
resolve this issue, I can provide my services on their contact. And believe me 
that if the Country Codes limitation will not be extended from 2 letters, the 
.IDN TLD will not be applicable till 2010 and even it is implemented, it has to 
be revamped again with in 6 to 12 months of its introduction.

2. Limitations of Utility & Usefulness:
ccNSO is planning for the IDN.IDN name & IDN ccTLD name to facilitate native 
languages users, but it is necessary that to point out that how the other 
community members will communicate with them, or even how they will be write 
down the exact letters with proper sequence in the browser and how the users 
will communicate their email address or website address to other community 
members which are not aware with their language. 

All the discussion was made on the level of DNS and Root Servers or Brosers for 
enabling the IDN naming convention, but is there any discussion made to address 
that how Email Servers & Clients will serve and recognize the IDN naming 
convention e.g. IBM Lotus Domino Server 6.x.x, MS Exchange Server 2000, 2003 
Servers etc. to facilitate these regional comminutes with team collaboration 

Proposed Solution:
If the above problems are justified and ccNSO or ICANN needs to resolve this 
issue, I can provide my services in this regards but to some extend.

3. Proposed Clients for new .IDN ccTLD:
It is necessary to discovered that what kind of planning is going to be formed 
for the issuance of new TLDs (IDN.IDN, .IDN, gTLD, ccTLD). 

Which of the following basis or criteria is proposed: 

1. "first come first serve" or 
2. "intellectual property rights only" or 
3. "by offering to existing registrars of other TLDs before allowing to Public?"
4. "by keeping in view to maintain Internet with through monopolists?"
5. "to selected companies assigned or authorized by regional government" 

Proposed Solution:
Reserving the intellectual property rights the first come first serve policy 
may please be adopted keeping in mid that the client has good ethics and really 
want to help their regional community.

4. Proposed Cost of new .IDN ccTL:
This has to be defined that what is the proposed cost for the registration of 
new .IDN ccTLDs and IDN gTLD. In year 2000 the fee (no-refundable) for New TLDs 
application was fixed by ICANN which was US$.50,000. (Ref: 
During the latest discussion on ICANN blog this has never indicated that how 
much cost will be charged for the registration of New TLD. If I am not wrong, 
this is very hard to justify the non-refundable fee of US$50,000/- to submit 
with an Application, if it is rejected. Similarly how the individuals or 
non-commercial organizations can pay this non-refundable fee.
If ICANN has planning for the bidding the new .IDN TLDs, one can expect that 
only richest companies (monopolist) will achieve the .IDN names. And Internet 
will go in the hand of monopolists. This is against the policy of transparency.
Similarly another clarification is most important and required that if someone 
propose or apply for the new TLD (if he is given a chance), what are the 
chances this proposed name is offered first to existing registrar of other TLDs 
and second it is sold to higher bidder (either bidding is open to the whole 

Proposed Solution:
However, it is suggested that the new TLD fee should not be so high, but the 
concurrent charges may be applied with each next 2 or 3 level domain names 
created with new TLD. This procedure will help to provide equal opportunity to 
the community of Internet world.

Once the above issues are resolved, policies and Project Management Process 
(PDP) can easily be prepared for formation FastTrack for IDNs and to accomudate 
maximum users of Internet.

Thanking you an Best Regards

Imran Ahmed Shah
Email: ias_pk@xxxxxxxxx, imran.shah@xxxxxxxxxxxx
Contact: +92-300-4130617 (Mobile)

What is a nonconformity?  According to the definition in ISO 9000: 2000 
(3.6.2), a nonconformity is "non-fulfillment of a requirement".

Attachment: Proposal for FastTrack on Introduction of IDN ccTLDs.doc
Description: MS-Word document

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