Comments on "Implementation Plan for Synchronized IDN ccTLDs"
Please find comments to "Implementation Plan for Synchronized IDN ccTLDs" below. Hiro Hotta, JPRS (.JP ccTLD) ===== comments ===== Thank you for giving us opportunity to comment on such an important issue - the Implementation Plan for Synchronized IDN ccTLDs. In my limited knowledge, I recognize that some mechanism such as synchronized IDN ccTLDs should exist for Chinese(Han)-script ccTLDs if IDN ccTLDs ever exist for Chinese-language community. Two strings were requested as IDN ccTLDs corresponding to .cn (and to .tw) and were claimed to resolve to the same address or value. I support the requester's claim that those two strings should coexist and should resolve to the same address or value for Chinese-language community. I believe there are cases where this kind of situation stand for other languages/script communities. Based on this belief, I recognize IDN ccTLD Fast Track Process should tolerate an extraordinary case that requires Synchronized IDN ccTLD mechanism and I would pay my respects for ICANN that has intention to create the procedure and make Synchronized IDN ccTLDs in existence. I comment on the following points on the process to approve the Synchronized IDN ccTLDs, taking a stance that Synchronized IDN ccTLDs under certain conditions should be accepted. (1) Traditional Chinese characters and Simplified Chinese characters coexist in one script (Han script) that is a written form of Chinese language. The requested two IDN ccTLD strings corresponding to .cn differ only by having the so-called 'variant characters', one of which has Traditional form and the other has Simplified form. Same applies to requested IDN ccTLD strings corresponding to .tw. Namely, more than one Chinese IDN ccTLD strings having variant characters, which are regarded as equivalent characters, are presented in ONE LANGUAGE and ONE SCRIPT. However, "2.1 Synchronized IDN ccTLDs" in the Criteria for participation says "more than one official language or script exists within a corresponding country/territory" is required. This requirement does not cover cases with variants in one official language and one script such as .cn and .tw cases. So, I comment that "more than one official language or script exists within a corresponding country/territory" be excluded from the definition of Synchronized IDN ccTLDs. (2) The procedure for convergence should not be a scheme to merely fix divergence which has already occurred, but a mechanism by which divergence cannot occur. Enforcing a procedure to bring divergence down is generally difficult when divergence ever takes place. Therefore, if adequately effective technical mechanism is in place at this moment, such mechanism should be clearly specified in this document as an example to address this issue. If such mechanism does not exist, procedure suggested by the requester will be evaluated using relatively vague criteria. However, the requirements laid out in page 4 do not clearly present criteria to judge how they are satisfied, which will lead to arbitrary evaluation based on different knowledge level and discretion of different evaluators. To address this, either of the following measures will be necessary : (a) clarify technical solution(s) that is secure enough, and obligate applicant to declare its compliance to the solution(s) (b) appoint evaluators with sufficient knowledge and ability to make judgment If measure (a) is nonexistent, taking measure (b) is practical. It is expected that requester proposes a full procedure to take care of the divergence. In addition, selection of very capable evaluators is expected. (3) In light of the original concept of "Synchronized", divergence must be eliminated. Section 5. of "Evaluation of Requests" in page 6 mentions "to remove any divergence that might occur". This should be interpreted that the measures involve removal of Resource Record(s) of (at least the second and further) proposed TLD(s) from the root zone at the last resort. Without this measure, the procedure is not regarded secure enough. It should be required for the requesters to indicate in the proposed procedure the way to shift to the state of convergence when new and safer technical solution(s) comes out, and when divergence occurs. In addition, a last resort process of removing Resource Record(s) of (at least the second and further) proposed TLD(s) should be added to the requirements for request for Synchronized IDN ccTLDs, in order to prepare for the case where divergence cannot be removed to a sufficient level. ====