[ALAC] Fwd: Re: CALL FOR COMMENTS: ALAC Statement on the Translation and Transliteration of Contact Information Working Group SO-AC Input Request

Tue Feb 18 19:14:32 UTC 2014

No, I din't think we are violently disagreeing, but my concern was 
that we not make a statement that does not bear up to scrutiny.

On the issue of users vs registrants, yes, it predates you. 
Registrants are represented in the GNSO, as both the CSG and NCSG use 
the word users, but their charters make it clear that it is 
registrants that is their focus (with the possible exception of the 
ISP const.). We are often in alignment with the Business Const, and 
even the IP const a lot of the time. But the NCSG has tended to focus 
on privacy issues more than other user-related issues, and we have 
therefore been at odds with them at times (an example of how 
protecting registrant rights could negatively impact regular users - 
Whois privacy). Which to some extent has convinced some in At-Large 
that we need to focus on some registrant issues. And since regular 
users are the customers of web sites and such, they are impacted by 
things that adversely affect registrants (such as losing their 
domains for some reason). Expiration issues and more recently 
hi-jacking are examples.

Regarding the specifics, in my mind, the entire issue focuses on the 
usability of Whois. If a registration is carried out in a 
language/script which cannot be rendered in 7-bit ASCII, then as long 
as Whois is stored and presented in 7-bit ASCII, what is in Whois 
must be a meaningful and usable version of the original data.

Alan

At 18/02/2014 12:39 PM, Rinalia Abdul Rahim wrote:
>Hi, Alan.
>
>Your detailed knowledge is always enriching and very useful.
>
>I don't believe we are in disagreement.  It is more a matter of approach.
>
>I don't think I have seen the push-back in the At-Large in 
>supporting registrants.  This may have predated my engagement.  In 
>principle, I see some value in supporting registrants in that they 
>provide content and services for end users.  And certainly we should 
>not be supporting them in cases where it harms end users.
>
>In moving forward on this, I think the ALAC needs to make a 
>decision.  As you mentioned there is a myriad of activities on the 
>topic from various groups.  I don't believe we are ready with 
>detailed responses on each of the questions - it is also possible 
>that end user comments on most of the questions are 
>non-existent.  What might be helpful to "influence" the thinking on 
>policy options within those groups is to convey what the ALAC 
>considers as the principle early on.  If the principle is conveyed, 
>then the ALAC can see what policy options are generated and say 
>"yes, we support this" or "no, we reject this" based on the principle.
>
>
>Best regards,
>
>Rinalia
>
>
>On Mon, Feb 17, 2014 at 1:01 PM, Alan Greenberg 
><<mailto:alan.greenberg at mcgill.ca>alan.greenberg at mcgill.ca> wrote:
>I know of no cases where an explicit translation/transliteration fee 
>is charged. The entire domain registration process is ultimately 
>largely funded by registration fees, to the extent that we are privy 
>to registrar and registry internal finances (perhaps some registrars 
>subsidize registrations with income from other lines of businesses, 
>but that is beyond our knowledge or control). So if there is a T/T 
>cost, it is ultimately either explicitly charged to registrant (not 
>likely in my mind) or buried in the overall costs of the registration.
>
>I wasn't trying to make any stronger point that to say that since 
>most costs associated with registrations are incorporated in 
>registration fees, we need more specificity than simply saying the 
>registrant shall not pay.
>In today's ASCII world, if a registrar is required to create an 
>ASCII Whois record (as they are!), and the registration is done in 
>some other script, then somewhere a conversion needs to be done. 
>Today, to the extent that they honour the RAA requirement, the 
>registrar needs to create ASCII text that goes into the Whois 
>record. So they bear the cost. If I understand your point, you are 
>saying that this cost must be born by the registrar as a cost of 
>doing business and should not explicitly be levied on the 
>registrant. I don't think we can say anything stronger. There is no 
>way we can control (or even recognize) that a domain is more 
>expensive in Beijing than in Dallas and attribute it to the T/T cost 
>(as opposed to cost of rent or taxes or bribes!).
>Regarding whether we should advocate for registrants, instead of 
>just "users". There was a lot of push-back in At-Large when I 
>advocated such actions. The balance that we struck (and it is not 
>violated in this case) is that to the extent that advocating for 
>registrants does not measurably harm non-registrant users, then we 
>are definitely in the business of supporting registrants.
>Alan
>
>At 16/02/2014 10:32 PM, Rinalia Abdul Rahim wrote:
>>Alan,
>>What a multiplicity of effort.  One wonders if anyone ever gets 
>>confused in ICANN.
>>On your comment regarding registrants pay ALL of the cost for 
>>translation and or transliteration - Can you clarify if that is an 
>>assumption based on examples in other areas implicating registrants 
>>or are there registrants that are currently required to translate 
>>or transliterate when they register?
>>Here is my view:  The core/fundamental consideration in translation 
>>and / or transliteration is whether it is meant for general use or 
>>specialized use.   If the former, the principle should be that the 
>>cost is borne by the process that collects the information (i.e, 
>>registry/registrar).  If the latter, the entities requiring 
>>translated/transliterated data pay for the specialized 
>>service.  The key issue is whether or not the principles can be 
>>enforced so that the cost is not transferred to registrants.
>>The ALAC should make a stand on the issue on behalf of the 
>>registrants, who comprise part of the consumer group that it 
>>advocates for.  It should begin by saying that under no 
>>circumstances should the Registrants have to pay for it and steps 
>>must be taken to ensure that costs are not transferred to 
>>registrants (which among others would include the requirement of 
>>information transparency to track price differentials etc as you 
>>mentioned in your mail).
>>Best regards,
>>
>>Rinalia
>>
>>
>>
>>On Mon, Feb 17, 2014 at 10:59 AM, Alan Greenberg 
>><<mailto:alan.greenberg at mcgill.ca>alan.greenberg at mcgill.ca > wrote:
>>Ultimately, registrants pay ALL of the costs, since they are the 
>>only significant source of funding. The only substantive issue 
>>(that I see) is how much obfuscation there is in tracing and 
>>attributing any translation/transliteration cost and whether the 
>>registry/registrar can be seen to be charging differential fees 
>>based on whether T/T is needed. The only other potential funder is 
>>those who look at the data, and that is a MUCH smaller pool by 
>>several orders of magnitude and not likely a useful source for 
>>funding what may be a significant cost.
>>Note that presumably the Registration EWG is working with an 
>>assumption that the great new registration system in the sky will 
>>not be limited to 7-bit ASCII, so the question that they are 
>>looking at is different from the one today where we are, for the 
>>known future, subject to that limitation. I note that there is 
>>ANOTHER expert working group looking specifically at the T/T issue 
>>in parallel with the PDP.
>>NOTE TO STAFF: In converting the e-mail at the start of the 
>>workspace to PDF format, all of the hyperlinks to the background 
>>documents were lost.
>>Alan
>>At 16/02/2014 08:05 PM, Rinalia Abdul Rahim wrote:
>>Thanks for the information, Carlton.
>>Olivier, the ALAC needs to decide if it wishes to submit a view to the WG
>>at this stage or wait to see the EWG view on the matter.
>>An option to consider:
>>For now, send a simple, but clear message to the WG that says the ALAC
>>firmly believes that Registrants should not have to bear any of the cost
>>burden for translation and / or transliteration of registration contact
>>data.
>>The rest of the issues may benefit from waiting and hearing the EWG view,
>>the At-Large Registration WG view + the At-Large IDN WG view, which will
>>take time.
>>There will be calls for comments on the EWG work as well as the Translation
>>Transliteration WG work in the future, so there will be future
>>opportunities for providing input on the more complex aspects of the
>>issue.
>>Best regards,
>>
>>Rinalia
>>On Feb 17, 2014 8:36 AM, "Carlton Samuels" 
>><<mailto:carlton.samuels at gmail.com> carlton.samuels at gmail.com>
>>wrote:
>> > FWIW, the specific issue of whether translations should be provided for
>> > registration data for directory services is under active 
>> discussion in the
>> > EWG.
>> >
>> > -Carlton
>> >
>> >
>> > ==============================
>> > Carlton A Samuels
>> > Mobile: <tel:876-818-1799>876-818-1799
>> > *Strategy, Planning, Governance, Assessment & Turnaround*
>> > =============================
>> >
>> >
>> > On Sun, Feb 16, 2014 at 1:20 AM, Rinalia Abdul Rahim <
>> > <mailto:rinalia.abdulrahim at gmail.com>rinalia.abdulrahim at gmail.com> wrote:
>> >
>> >> Dear Olivier,
>> >>
>> >> I believe the questions posed to SO/AC  from the Translation
>> >> Transliteration of Contact Information WG requires At-Large scrutiny
>> >> beyond
>> >> the IDN Working Group.  The Registration Issues WG, among 
>> others, may have
>> >> a view on some of the key issues.
>> >>
>> >> The question of who should pay for translation and / or transliteration,
>> >> for example, may implicate registrants.  This question is linked to the
>> >> purpose and benefit of contact data transformation, which is a higher
>> >> level
>> >> issue.
>> >>
>> >> Best regards,
>> >>
>> >> Rinalia
>> >>  Dear Staff,
>> >>
>> >> I note the request for feedback.  I think the format in which 
>> the request
>> >> is made will deter responses.  Specifically, the questions posed are
>> >> buried
>> >> in a PDF document and not highlighted for appropriate attention.
>> >>
>> >> Action Needed:
>> >> 1. Please lift the questions out of the mail from Glen and highlight
>> >> prominently on the wiki page.
>> >> 2.  Please number the questions so that people can identify the 
>> ones that
>> >> they are responding to and so that it would be easier to aggregate and
>> >> analyze the response.
>> >>
>> >> Thanks.
>> >>
>> >> Rinalia
>> >>
>> >>
>> >> On Thu, Feb 13, 2014 at 9:35 AM, ICANN At-Large Staff <
>> >> <mailto:staff at atlarge.icann.org>staff at atlarge.icann.org> wrote:
>> >>
>> >> > Dear Edmon and Rinalia,
>> >> >
>> >> > Please note that the At-Large Translation and Transliteration 
>> of Contact
>> >> > Information Working Group SO-AC Input Request Workspace<
>> >> 
>> <https://community.icann.org/x/bgDRAg>https://community.icann.org/x/bgDRAg>
>> >> >  has been created. Please note that this workspace will be used to
>> >> gather
>> >> > the At-Large's comments on this Input Request
>> >> >
>> >> > Please submit any comments on the workspace using the 
>> comments function
>> >> by *28
>> >> > Feb 2014 23:59 UTC*.
>> >> >
>> >> > Regards,
>> >> >
>> >> >
>> >> > Heidi Ullrich, Silvia Vivanco, Matt Ashtiani, Gisella Gruber, Nathalie
>> >> > Peregrine and Julia Charvolen
>> >> >
>> >> > ICANN Policy Staff in support of ALAC
>> >> >
>> >> > E-mail: <mailto:staff at atlarge.icann.org>staff at atlarge.icann.org
>> >> >
>> >> >
>> >> >
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>> >>
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>> >> 
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>>
>> >>
>> >
>> >
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