Introduction of IDN ccTLDs - Important Suggestions for Policy preparation of FastTrack
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 FastTrack. 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 http://unstats.un.org/unsd/methods/m49/m49alpha.htm) 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 tools? 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: http://www.icann.org/tlds/application-process-03aug00.htm) 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 world)? 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".
Proposal for FastTrack on Introduction of IDN ccTLDs.doc