[NCSG-PC] Public comment on spec

[farzaneh badii]

Hi

We are late but we have drafted a one paragraph which we need to submit
tomorrow in response to a call for public comment on spec 14.
Yao has come up with an excellent system for NPOC which we can use.(have to
check with him)
 If you have other comments let me know.

Specification 14 - Variant TLDs: Registrant Choice and Bundling Concerns
NCSG is concerned that Section 2.15’s mandatory bundling of variant
second-level domain names across TLD Sets inadequately considers registrant
autonomy in multilingual contexts. While we understand the technical
rationale for preventing confusion through unified allocation, requiring
that “all second-level domain names, and any allocatable variants thereof,
under the TLD Set is either allocated to the same registrant, or else
withheld for possible allocation only to that registrant” creates a forced
bundling mechanism that could increase costs and reduce flexibility for
community organizations, civil society groups, and individual registrants
operating across multiple scripts and languages. This is particularly
problematic for communities where different organizations may legitimately
represent the same concept or entity in different linguistic or cultural
contexts. We recommend that ICANN develop clearer guidance on how
registrants can decline variant bundles they do not need, ensure pricing
structures do not penalize those required to hold variants they have no use
for, and consider whether exceptions should be available for demonstrated
community need where different parties have legitimate claims to variants
in different scripts. The specification should explicitly preserve
registrant choice rather than defaulting to mandatory acquisition models
that primarily serve registry operator administrative
convenience.​​​​​​​​​​​​​​​​


Farzaneh
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