CNNIC Reply to the the interim report of Examining the User Experience Implications of Active Variant TLDs

[Hongbin 朱鸿斌 <zhuhongbin@xxxxxxxx>]

To whom it may be concerned,

 

Many thanks to the VIP team for inviting CNNIC to participate in the
research project of IDN variant user experience. The interim report of IDN
variant user experience has included much of our input on Chinese IDN
variants operation. Nevertheless, hereby I would like to express more of our
concerns.

 

It is acknowledgeable that properly solving the IDN variant issues is
critical not only for the security and reliability of the DNS operation, but
also for the linguistic and cultural integrity from the perspective of many
non-ASCII communities. According to our operating experience, end users
strongly expect the variant TLDs to be delegated and used simultaneously for
better user experience, since the variants are recognized as the same
meaning. We see this interim report raised many challenges about the IDN
variant user experience, which may increase many concerns on its technical
issues.  In fact when you look at these challenges, many of them are caused
by the current lack of acceptance and scarcity of IDN TLDs, especially the
variant TLDs comparing with ASCII ones. This situation can be better off by
introducing more IDN variant TLD to the root quickly and smoothly in
consistence with the current accepted practices, since emerging variant TLDs
will help to cultivate the market acceptance and the awareness of software
vendors with the joint efforts of IDN communities. If many IDN variant TLDs
are hold back, the user experience will be challenged and all the challenges
cannot be solved efficiently in time with such little awareness among the
software vendors and new registries. It is also predictable that new
challenges will constantly show up. 

 

It is also mentioned in the interim report that some ccTLD registries have
already operated IDN variant TLD for years. There are no outstanding
operation issues up to date, so it is not true that introducing IDN variant
TLD efficiently will bring up significant security problems.

 

Meanwhile, considering that IDNs are now getting prioritized in the new gTLD
evaluation process, we want to address one of our concerns for the time
schedule of variant issue project. It is obvious that almost all the
applicants do not want their TLDs to be disadvantaged because of late
delegation. There is one practical concern from us. Although the IDNs are
claimed to be prioritized, it is still not clear that IDN variants can be
delegated first. In fact, the IDN variant issue project is still ongoing,
which put much uncertainty for the IDN variants can be delegated to the root
simultaneously. We are very concerned about whether the IDNs can be
delegated on time for better serving our registrants and end users. 

 

In addition, the IDN variant issue is also more complicated for contracting
with ICANN. From our experience, unlike the ASCII domain names which will
lead to immediate acceptance of standard contract, IDNs need more time for
negotiating the fee structure and its compliance to TMCH rules. Therefore we
think if the IDN prioritization need to be reinforced, all the necessary
preparation for IDN delegation in the root, including the Variant Issue
research project, shall also be conducted in a efficient manner as
consistent with the pace of IDN delegation. If not, the IDN community will
still be disadvantaged in competition with ASCII TLDs. The original goal of
IDN prioritization will be hampered.

 

I hope ICANN and VIP team can address these problems and give us more
clarification on the estimated time for IDN variants TLD delegation, and
what are the requirements for IDN variants delegation, in order to make sure
that IDNs can really get prioritized for the public interests.

 

 

Regards,

 

Hongbin Zhu 

 

Senior Policy Strategist

China Internet Network Information Center