Comments on ICANN IDN Guidelines V 2.0

[Abdulaziz Al-Zoman <zoman@xxxxxxxxxx>]

Dear ICANN,

The following are comments as a response to the request for comments
on the âICANN Guidelines for the Implementation of Internationalized 
Domain Names, Draft v2.0â.

These comments are from the Steering Committee of the Arabic Domain
Names Pilot Project (www.arabic-domains.org).


*  Unfortunately, the ICANN IDN Guidelines V.2 is still working on
   a handicapped IDN solution (i.e., ML.English) that does not
   support full IDN on a TLD level (i.e., ML.ML).

*  The ICANN IDN Guidelines V.2 reflects the experiences of the
   IDN registries who have implemented version 1.0 (i.e.,
   registries which provide ML.English, such as VerSign).
   This excludes the experiences collected by different entities
   around the world who strive to support their languages on
   domain names.

*  The current IDN implementations as suggested by the ICANN IDN
   Guidelines V. 1.0 and 2.0 (i.e., ML.English) still are not
   suitable for languages that are not Latin-based, for example,
   languages written from right-to-left (e.g., Arabic, Farsi,
   Urdu) or ideographic languages (e.g., Chinese, Japanese,
   Korean).

*  A more practical approach even for testing proposes is to start
   the IDN support at a ccTLD level rather than on a gTLD. So that
   the TLD is written in a specific language (e.g. Arabic) that
   will be supported on the SLD controlled by a character set
   table. In this case characters from other scripts (e.g., Farsi,
   Urdu, â)  will not be confused with visually confusable
   characters.

*  It is strongly believed that concerns and issues that are
   raised by the guidelines regarding IDN implementations would
   be addressed when internationalizing ccTLDs are supported.

*  The Arabic domain names pilot project  (www.arabic-domains.org)
   supports the following principles that have been stated in the
   proposal submitted by the Chinese Domain Name Consortium (CDNC)
   (www.icann.org/announcements/idn-tld-cdnc.pdf) to ICANN,
   namely:

   -  Give the priority to internationalizing ccTLDs. To ensure
      the system stability, itâs recommended to internationalize
      ccTLD before internationalize gTLD.

   -  For convenience purpose, only one form of language character
      variant of internationalized ccTLD is accepted. Considering
      that some countries or regions may have character variants,
      only one form of character sets shall be chosen for IDN use
      by each sponsored registry.

   -  Supported by their own governments, ccTLD registries or
      authorized agencies make their own choice of which IDN
      character sets for their ccTLDs.

   -  Register and operate the internationalized ccTLDs in the
      root DNS server in the form of IDNA Punycode.


Thank you for giving us the chance to express our opinion.


Best regards,

On behave of the Arabic Domain Names Pilot Project

Dr. Abdulaziz H. Al-Zoman
Chairman of the Steering Committee (AND Pilot Project), and
Director of  SaudiNIC (.sa ccTLD Registry)
zoman@xxxxxxxxxx