[NCSG-PC] [urgent] Re: Review on the draft Recommendations for Managing IDN Variant Top-Level Domains

Tue Sep 18 12:42:48 EEST 2018

Hi Farzaneh,

I was part of the drafters' team and I must confess that I did not put too much effort on the work since I was also concerned with other Public Comments that required an effective attention from me, too.

Not only the question asked and the IDN issues as a whole require a high technical knowledge and experience with the subject, but also there was a lot of documents to read and a strong background to have before writing something. I went through all the docs but I could not answer most of the questions with enough confidence within the time slot proposed. If you still can, don’t hesitate, go ahead and edit the draft. However; there is no issue/problem not answering all the questions…. We can write “no answer” or “NIHIL”. 

As far as not submitting a comment here (in state or not), I must refer to Rafik, the policy Chair whose vision is rather to always comment/acknowledge on/a calls.

Regarding the questions and in my opinion, 1 is yes, 2a is yes, 2.b is possible (but needs further discussions within NCSG) 3 is mostly yes but with some nuances to clarify. For 5, I am unable to answer by now (further reading and IDN knowledge to gain). Regarding the 6th, what you are describing seems to be a valid additional risk, and there may be many others to add but with strong rationale (to describe and to simulate their impacts)

That’s it!

@__f_f__

Best Regards
____________________________________

(Ekue) Farell FOLLY
NCUC Rep. to the NCSG Policy Committee
linkedin.com/in/farellf 

> On 18 Sep 2018, at 05:52, farzaneh badii <farzaneh.badii at gmail.com> wrote:
> 
> Hi All
> 
> I know we are all overburdened with a lot of work and I thank whoever drafted this document. But I think this comment needs further improvement. We are not really addressing the issues that the report is asking for.
> I pasted the questions. I am sorry I am of no help, I really don't have the time to read carefully but here are my observations: 
> 1. I think something pertinent to question 3 and 4 (and I might be wrong) is that if they want to again delegate the name of the countries in IDN to the cctld managers, these managers should not be allowed to use UDRP service providers such as WIPO.  (I don't know how far they go, do they delegate  similar names of countries and territories -overreach alert- or exact names? I could not figure out)
> Why am I against that? Because even in non IDN ccTLDs we see trademark overreach. Amazon has claimed so many domain names that have had similarities to Amazon in ccTLDs that Amazon did not even have any business at!!! Rest assured that this is going to happen to IDNs as well. Note that processes such as WIPO are most of the time only in English.
> If we are defenders of diversity I think this is where we should act! 
> 
> Anyhow. I might be wrong. As I said it was a cursory review and general knowledge.If we cannot elaborate on the questions below, then I think we should not submit the comment in its current state.
> 
> Questions that were asked:
> 
> The rationale for the RZ-LGR requires strictly adhering to the IDN variant label sets defined by the community through the RZ-LGR. Is this a reasonable pre-requisite for implementing IDN Variant TLDs?
> Do the proposed recommendations appropriately address the management and implementation of the IDN Variant TLDs?
> Do any suggested recommendations need to be changed? Why?
> Are any additional recommendations needed?
> Does the analysis suitably cover the impact of the recommendations on existing procedures for IDN ccTLDs and IDN gTLDs? Is there alternate analysis for certain cases? Are there any additional impacts on the procedures not identified?
> Which (if any) of the recommendations require policy consideration by GNSO and ccNSO, whereas the remaining would only have an impact on procedures?
> To prevent the permutation issue which can be introduced by using variant labels, as identified by SSAC, how may the allocated IDN Variant TLD labels be limited? Are the mechanisms suggested in Appendix C appropriate? What other factors may also be relevant?
> Are the risks and their mitigation measures sufficiently comprehensive? Are there any additional risks? Should there be different or additional mitigation measures?
> Farzaneh
> 
> 
> On Mon, Sep 17, 2018 at 8:08 PM Rafik Dammak <rafik.dammak at gmail.com <mailto:rafik.dammak at gmail.com>> wrote:
> hi all,
> 
> the deadline passed but it is possible to submit. please chime in
> the draft comment is quite short.
> 
> Best,
> 
> Rafik
> 
> Le lun. 17 sept. 2018 à 22:06, Rafik Dammak <rafik.dammak at gmail.com <mailto:rafik.dammak at gmail.com>> a écrit :
> hi all,
> 
> please review the draft statement, the deadline for submission is today.
> 
> Best,
> 
> Rafik
> 
> Le sam. 15 sept. 2018 à 16:44, Rafik Dammak <rafik.dammak at gmail.com <mailto:rafik.dammak at gmail.com>> a écrit :
> Hi all,
> 
> please review the draft comment https://docs.google.com/document/d/19IIt4o1kSwN2o0aJJ09IL1Qh49GVdlps2QLdhmpA0BI/edit <https://docs.google.com/document/d/19IIt4o1kSwN2o0aJJ09IL1Qh49GVdlps2QLdhmpA0BI/edit>. the deadline for submission is the 17th September.
> 
> Best,
> 
> Rafik
> 
> 
> ---------- Forwarded message ---------
> From: Farell FOLLY <farell at benin2point0.org <mailto:farell at benin2point0.org>>
> 
> 
> 
> Dear All,
> 
> This is another public comment on the IDN for review. It is a brief comment but all new suggestions are welcome. The deadline is to the 17th of September.
> 
> https://docs.google.com/document/d/19IIt4o1kSwN2o0aJJ09IL1Qh49GVdlps2QLdhmpA0BI/edit <https://docs.google.com/document/d/19IIt4o1kSwN2o0aJJ09IL1Qh49GVdlps2QLdhmpA0BI/edit>
> 
> @__f_f__
> 
> Best Regards
> ____________________________________
> 
> (Ekue) Farell FOLLY
> NCUC Rep. to the NCSG Policy Committee
> linkedin.com/in/farellf <http://linkedin.com/in/farellf> 
> 
> 
> 
> 
> 
> 
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