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RE: [gtld-com] Regarding seeking public comment onthe committee'sdraft


There were several organizations, including NeuStar/NeuLevel, that filed
extensive comments to these specific provisions, which in our opinion took
an overly simplistic view of these issues.  

I cannot find where our responses are located on the ICANN Website, but if
we are going to cite that particular report, then lets include all of the
responses to that document.



-----Original Message-----
From: Milton Mueller [mailto:Mueller@syr.edu]
Sent: Wednesday, April 16, 2003 11:23 AM
To: gtld-com@dnso.org; vinton.g.cerf@mci.com;
Bruce.Tonkin@melbourneit.com.au; Milton Mueller
Cc: twomey@icann.org; vcerf@MCI.NET
Subject: Re: [gtld-com] Regarding seeking public comment onthe

Sorry to bother you all again. But Danny Younger has 
brought to my attention a discussion paper that 
addresses the IDN - TLD issues. 

Discussion Paper on Non-ASCII Top-Level Domain Policy Issues

The paper provides a balanced view of the pros and cons. 
I reproduce below the most relevant parts (seems that we
have been reinventing the wheel on the Council gTLD-committee.)




By "semantic association with an existing sponsored gTLD," we mean a 
non-ASCII TLD string that to a typical reader would be clearly linked to an 
existing ASCII sponsored TLD.  Currently, that list includes .aero, .coop, 
and .museum.  For purposes of this paper, the category arguably includes
.edu and .int also.  A example of a non-ASCII TLD semantically associated
with .museum would be the TLD string consisting of the Hangul (Korean)
characters meaning "museum" in Korean.

The issue with this group is twofold: Firstly should existing registry 
sponsors have a right to TLD strings in non-ASCII characters with the same
semantic meaning as their ASCII TLD string?  In other words, should they be
given a preference, or be treated the same as any other proposer? Secondly,
if one language variant is approved for a given sponsored TLD does this
automatically imply a right to all other language variants? 

Advantages of incumbent preference:

Giving a preference for equivalent non-ASCII strings to existing ASCII 
sponsored registries would be simple, and somewhat logical.  Once ICANN has
concluded that a given sponsor is an appropriate proxy and policymaker on
behalf of the community to be served by the TLD, it could logically be
considered to have equivalent legitimacy across non-ASCII TLD strings as
well.  This might also lead to less confusion among users, in that 
registration rules and registries policies would be consistent. 

Disadvantages of incumbent preference:

The selection of TLD registries is complicated.  A representative sponsor
for an ASCII TLD may not be best for all communities, particularly where the
scope of a given script's use is highly localized.  For that reason, it may
be best to place no hard rights or prohibitions on the allocation of TLD 
strings with semantic association to existing sponsored TLDs, treating them
as any other new TLD, open to any proposer, but also allowing the existing
ASCII TLD registry sponsors to present proposals for equivalent non-ASCII
TLDs, with relevant justification for their role. 
Each TLD string should be treated differently, and should be open for 
proposals to any potential registry operator that can establish the basic 
requirements for a sponsored TLD, including support within the community to
be served.  At the same time, it may be possible for a single organization
to demonstrate its legitimacy and capacity to serve as a global coordinating
registry for a given term (i.e., "museum") as to all non-ASCII strings
consisting of characters that have the equivalent semantic meaning in some



By "semantic association with existing unsponsored gTLDs", we mean a 
non-ASCII TLD string that to a typical reader would be clearly linked to the

an existing unsponsored ASCII gTLD, such as .com, .net, .org, .info, .biz,
or .name.

Here again, the issue is whether to give any advantage to the current 
registry operators of the existing ASCII unsponsored gTLDs.

Advantages of incumbent preference:

There appear to be few notable advantages, other than for the existing 
registry operators themselves.  It should be noted that several current
operators of gTLD registries have pointed to a range of arguable advantages,
from their perspective, including: ease of transition,
single-point-of-registration services for registrants, consistency and
stability of applicable registration rules and policies, and minimization of
consumer confusion between semantically-equivalent ASCII and non-ASCII TLDs.

Disadvantages of incumbent preference:

Given the generic nature of the terms at issue, and the wide-ranging 
complexities of meaning across languages, it would be extremely difficult to
determine which non-ASCII words and abbreviations should qualify for the
preference; indeed, it is not clear why the preference would not also 
logically extend to ASCII TLD strings, such as "company" for the .com 
registry operator.

The principles of registry-level competition and geographic distribution of 
registries both argue strongly against giving any preference to existing 
ASCII gTLD registry operators.  Such a preference would promote market 
concentration, rather than competition." 

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