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Comments on the Draft Final Report

  • To: idn-cctld-fast-track@xxxxxxxxx
  • Subject: Comments on the Draft Final Report
  • From: Paul Hoffman <phoffman@xxxxxxx>
  • Date: Sat, 14 Jun 2008 17:27:58 -0700

The Draft Final Report of Recommendations for Fast Track seems like a very complete document. It covers all the issues that probably should be covered for the fast track IDN ccTLDs. The following are suggestions for the IDNC WG to consider as they finalize the report.

1) The requirement that the IDN ccTLDs have "language tables" is out of place and could easily be removed. As shown by the IANA registry at <http://www.iana.org/domains/idn-tables/>, very few ccTLDs that allow IDNs have published tables. Although these tables may be useful, they are clearly not required, and lacking them should not prevent an otherwise-valuable IDN ccTLD from being registered.

2) Guiding Principle D (Fast Track only for non-Latin scripts) could be dropped. Of course, this is another of those "politically tricky" topics at ICANN, but it really should be considered. When IDNs were developed, they were meant to be nearly equivalent to "regular" DNS labels. Making all-ASCII country names second-class citizens in the fast-track process is inherently unfair to many countries whose country names in their native languages could otherwise meet all the other guiding principles. In other words, why should Spain's name be considered but Norway's names not be?

3) Guiding Principle F (The Fast Track is experimental in nature) is very confusing. What does it mean to be "experimental" if the delegations are not temporary? This should be clarified or, probably, just dropped.

4) It is very inappropriate to make any requirements at all concerning complying with IDNA2008. That new protocol is in the very early stages of discussion (the first Working Group drafts have had light consideration), so it is impossible to guess what the final outcome will be. The IETF generally frowns on standardizing on protocols before they are complete and approved; any body standardizing on very early drafts are taking huge risks.

5) The technical requirements list on page 8 is heavily based on early drafts of IDNA2008 and has many ambiguities. The list could be much shorter and clearer. The "no mixing of scripts" bullet is particularly worrisome because of the variety of meanings of the word "script". There is no technical need for the next-to-last bullet, and the last bullet is completely garbled. The last part of the last bullet ("does not create rendering problems in URLs, Email addresses etc., when in use") sounds like it prohibits any territory name in Arabic; if so, that seems quite inappropriate.

6) The members of the IDNC WG should be listed in the final report. It is actually quite difficult to find the membership listing on the ICANN site. As a side-note, in the listing in the report, members with non-ASCII characters in their names should have their names properly spelled.

I hope these comments help the IDNC WG come out with a more useful report.


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