Comments by Association Uninet

[Iliya Bazlyankov <iliya@xxxxxxxxx>]

Association Uninet represents three of the biggest domain registration
and web hosting companies in Bulgaria, as well as Internet providers
and IT companies.

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I strongly support the creation of an IDNgTLD constituency.

The two comments, submitted by Phil Shepard are focused on what he
calls the "policy challenge". One is on behalf of the Business
Constituency, of which he is a co-leader for many years and the other
is on behalf of the Business and ISP constituencies together. Both
constituencies are seeking to renew themselves under the same
Commercial Group of the non-contracted party side of the proposed
bicameral GNSO house. The trademark constituency (third one) is also
seeking renewal within this group. The new IDNgTLD constituency is the
only other that seeks to join this  commercial group after 5 years of
debate of how to reform the GNSO. The other two proposed
constituencies (cybersafety and consumers) seek to join the
non-commercial group. There is another comment submission by Marilyn
Cade, who has with Phil co-led business constituency for many years,
that also makes the same point, but in her individual capacity.

The "policy challenge" is simply the idea that the IDNgTLD
constituency is a "single issue" constituency – that it focuses on one
narrow thing and has to be barred. This view seems rather naive - it
is like saying that all of ICANN for a decade has been a single issue
and very narrow constituency/group - a single English/ASCII language
domain constituency. This view is representative of ICANN in general
(hopefully limited to before reform) - that the world is either
English or non-English, and that the non-English speaking world is a
“single” issue. It seems odd that always the only people who seem to
categorize the world this way are essentially native English speakers,
even if they come from different countries.

Milton Mueller points out correctly that IDNs will affect whois,
security and trademark, as well as the choice of new gTLD strings and
local language/culture registrar policies and that those things will
not be discussed in the context of Latin scripts/cultures. Moreover,
he points out that the existing trademark constituency is a single
purpose vehicle and that they are a subset of the ISP constituency and
the Biz constituency. If somebody argues that ISPs are Internet
businesses, he could advise that all the three commercial group
constituencies can be merged in one single Business constituency, led
by Phil. This Business constituency can also be represented as a
single issue – that of making money. In contrast, an IDNgTLD
constituency can encompass the scripts, cultural values, linguistic
description (technical and otherwise), grammar, humor, history, values
of the entire cultures/existence of more than half the planet's 7
billion linguistically-varied people.

Going outside of the GNSO, one can argue that the registrar community
is also a simple straightforward single issue vehicle - the middleman,
a simple role played through all time and in all cultures. Admittedly
all this gets to be silly at some point.

If the Business and the ISP constituencies argue that the IDNgTLD
constituency is about a single issue, the above argument would suggest
that many precedents have existed and will exist, including the
mentioned ISP and Business constituencies. One would imagine that
denying the  IDNgTLD on these grounds should logically preclude both
the ISP and Business constituencies from renewing under the GNSO
reform.

Marilyn Cade rightly points out that the IDN issue is a very broad one
and perhaps should be deferred to another more global accommodation
into ICANN structure, maybe to one that will cause another ten years
of debate. Most of her comment in her individual capacity suggests
that the IDN issue is too broad to fit in a constituency and should be
rejected. Oddly, a small part of her comment suggest that the IDN is a
single issue constituency and there appears to be an inconsistency
with the rest of her comment.
Her colleagues in the Business constituency are taking the formal
position of saying that the IDNgTLD constituency is a single issue and
therefore should be rejected for being too narrow. One would imagine
that the Business and ISP constituencies will also logically opine
that the proposed cybersafety and consumer groups are both single
issue and therefore should be rejected.

With the above arguments, one could suggest that all the three
existing constituencies in the commercial group, the proposed IDNgTLD
constituency, and the only two other new constituencies should be
thrown out altogether. Then only the contracted party registrars and
registries should be left under the notion that they alone are not
single issue since they alone presumably have more than the one issue
they are contracted for - to make $$$ via privileged, limited license.

Well, we could guess that such scenario would be a reform, too. At
least we will give up the pretense and simply run it as an industrial
consortium of big companies managing/regulating themselves and  find
better things to do with our time. At least there will be clarity and
focus centered around the single issue of making money under whatever
amounts to market forces in the current era.

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Kind regards,
Iliya Bazlyankov
Chairman of Association Uninet

http://www.uninet.bg
iliya@xxxxxxxxx