Comment from Verisign, Inc.

["McAuley, David" <dmcauley@xxxxxxxxxxxx>]

Verisign acknowledges and compliments the EPSRP Working Group for the effort 
undertaken to develop further policy guidance for the Extended Process 
Similarity Review Panel relating to the IDN ccTLD Fast Track process, and we 
thank the Working Group for this opportunity to comment on the results of its 
deliberations. We offer the following comment:

IDNs are an important development in ensuring broad, global access to the 
Internet. Every effort should be made to ensure that they are appropriately 
treated so that they may fulfill their promise in a manner that preserves the 
security, stability, and resilience of the Internet and the DNS. Such 
appropriate treatment would include, among other things, having due regard for 
RFC 6912.

We trust that the proposed guidelines and refinements being commented upon in 
this instance will aid in the string similarity review process that they will 
serve. But we also observe that in this and other processes IDN TLDs should be 
handled equivalently whether the string applied for is a new gTLD or a ccTLD, 
excepting only those facets of the process that relate to ccTLD strings 
strictly because and to the extent of their country-code nature.

David McAuley

David McAuley
International Policy Manager
Verisign Inc.
703-948-4154