[NCSG-PC] NCSG Public comment on Phase 2 Initial Report of the EPDP on IDNs

[Emmanuel Vitus]

Dear Comrades,
As the NCSG representative in the IDNs EPDP discussions, I am seeking your
feedback on the GNSO EPDP Phase 2 Initial Report on Internationalized
Domain Names, specifically concerning second-level variant management for
NCSG public comment.

 I found most of the report straightforward. However, I've identified three
specific areas that appear to require further review and consideration.

*Implementation Guidance 15: *This guideline proposes a standard approach
allowing registries or registrars to enhance services such as RDDS. These
services could offer comprehensive data about a domain and its variants,
possibly through advanced methods like bulk services. I suggest these
enhancements should remain optional and be tightly regulated to ensure
privacy and security.

*F1 Charter Question on TMCH:* The current "exact match" rules under the
Trademark Clearinghouse (TMCH) are too restrictive and could hinder
organizations whose names vary due to linguistic or branding changes. I
propose extending this rule to include "substantial matches," allowing
better protection for the intellectual properties of entities/orgs across
various regions and languages.

*Document Readability: *Although the report is well-structured, its
technical and legal jargon could be a barrier for non-commercial
stakeholders unfamiliar with domain name systems or trademark law. The
readability analysis shows a Flesch-Kincaid Grade Level of 12.96 and a
Gunning Fog Index of 16.37, indicating a high complexity level.

These are my primary concerns, though there may be other issues I'm not
aware of or you may disagree with my points. Please review the attached
document
<https://docs.google.com/document/d/1oeuAYEt-HHIaaD39rX-xRq5uRey2OPZ88z6VBXTPi7g/edit?usp=sharing>
containing my detailed comments and let me know your thoughts.

Feel free to reach out directly if you have any questions or need further
clarification. Colleagues  Akinremi Peter Taiwo,  Grace Githaiga, and Maju
are also monitoring this report and can assist with any inquiries. Great if
we can have all comments or questions by May 8, 2024.

Thank you for your attention and input.

Best regards,

Emmanuel
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