[At-Large] [IDN-WG] [APAC-Discuss] Draft Recommendations Overall Policy for the Selection of IDN ccTLD Strings PC

Rinalia Abdul Rahim rinalia.abdulrahim at gmail.com
Tue Oct 30 14:41:37 UTC 2012

Dear IDN WG and ALAC,

Please find below the revised statement on the* "Draft IDN ccTLD String
Selection Criteria, Requirements and Processes Policy Recommendations" *that
incorporates additions proposed during the Toronto meeting.  Suggestions
for further amendments *must be received by Friday (November 2nd)* for the
ALAC to commence a vote in time to meet the Reply Period deadline on
November 9th.


Rinalia Abdul Rahim*




*ALAC Statement on the Draft IDN ccTLD String Selection Criteria,
Requirements and Processes Policy Recommendations*

The At-Large Advisory Committee (ALAC) commends the International Domain
Names (IDN) country code Policy Development Process Working Group 1 for the
comprehensiveness of its draft policy recommendations on the IDN ccTLD
String Selection Criteria, Requirements and Processes for territories
listed in the ISO 3166-1 list.  We note that the recommendations are based
on the previous work of the IDNC Working Group and we are pleased to see
that the recommendations reflect the learning drawn from the implementation
of the IDNccTLD Fast Track Process over the past few years.

We observe that the draft recommendations do not address the issue of
variant TLDs and instead contain a placeholder in Section J, which points
out that issues pertaining to the management of such TLDs are still being
discussed in the ICANN community and will be added later.  We believe that
the draft recommendations should indicate that the issue of variants is
urgent and need to be addressed in a timely manner.  Concurrently, the
draft recommendations should also affirm that the outcomes of the variants
discussion pertaining to the Label Generation Ruleset (LGR) for the Root
Zone would be binding and applicable to all TLDs (including ccTLDs), given
that the overarching principle of the LGR process is the security and
stability of the Root Zone, which is shared by all Internet users.

We note with concern that the draft recommendations consider selected IDN
ccTLD strings to be confusingly similar based on their appearance to “a
reasonable Internet user who is unfamiliar with the script” although
"linguistic, technical, and visual perception factors" will be taken into
consideration.  Notwithstanding the merit and rationale for this assessment
criterion, an assessment on confusing similarity based primarily on the
appearance of selected strings to users unfamiliar with the script may not
be consistent with the nature and purpose of IDN ccTLDs, which are
fundamentally introduced for the use and benefit of local IDN users in
pertinent ccTLD territories.  Without taking into account sufficient
linguistic factors, problematic results may occur.  For example, an IDN
ccTLD that is assessed as not confusingly similar by a user "who is
unfamiliar with the script" may well be deemed confusingly similar by the
local IDN user and vice versa.  We believe that this particular issue can
be addressed in the policy making process through more consultations with
the IDN communities in implicated ccTLD territories.

Finally, we wish to reiterate the significance and importance of IDNs,
including IDN Top Level Domains (TLDs) at both the generic and country code
levels.  IDNs are crucial for enhancing diversity and multilingualism on
the Internet.  Towards this end, the attribution of IDNs should take into
account the fact that some languages have a wide geographical distribution
that go beyond national borders and are thus not the sole property of one
sovereign state alone.  It follows, therefore, that due consideration
should be given to protecting the rights of concerned language communities
which, though falling outside the jurisdiction of one nation state, share
with its inhabitants a common language or script.


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