draft IRD WG Interim Report comments

["Diaz, Paul" <pdiaz@xxxxxxxxxxxxxxxxxxxx>]

While Network Solutions appreciates the Working Group's efforts to date
on addressing Internationalized Registration Data (IRD) issues, we share
concerns expressed by others in this public comments forum.  In
particular, we would prefer to see additional models considered.  We
believe that Dr. Sarmand Husssain's proposal (see
http://forum.icann.org/lists/ird-wg-report/msg00000.html) to simply have
the Registrant provide IRD in the script and language of their choice
AND specify the language (locale?) of the data should be further
assessed.  In our view, its benefits include being simple to implement
while also shifting translation or transliteration responsibilities to
those who want to use the IRD.  

We also wonder why none of the proposed models have an explicit role for
the respective Registry Operator.  If the community accepts any of the
published proposals (other than Model 1, assuming US-ASCII7 would be the
"must be present" script), is it not reasonable to expect the registries
to provide - or at least endorse - a translation/transliteration
platform?  Perhaps the Working Group has not yet reached this point of
the debate, but it seems unrealistic for the Interim Report to only
spell out scenarios in which the Registry Operator remains in the
background.  Registries must be active partners in ensuring the
consistency and quality of IRD.  Failure to exert leadership will lead
to misunderstandings and undermine support for internationalized domains
- none of which is in the broader public interest.

Finally, we believe that there needs to be more discussion of
translation/transliteration tools if the community seriously considers
any of the IRD models that would require them.  The Interim Report
identifies several potential problem areas, but isn't clear if there's a
reasonable way forward.  It's rather difficult to comment on the
viability of several of the proposed models if the ICANN community
doesn't have a clear sense of the availability and veracity of existing
translation/transliteration tools.  This may be something of a "chicken
and the egg" issue, but we feel the debate would significantly benefit
from deeper analysis.