[NCSG-PC] Public comment on spec

[farzaneh badii]

Here is what our penholders have drafted:
https://docs.google.com/document/d/1hxr_WoU0tidEu6dgdZ0mbcgwEVrsIcYHud9ZgfeXui0/edit?usp=sharing


Submitting it in a few hours.


Farzaneh


On Tue, Jan 27, 2026 at 12:32 AM farzaneh badii <farzaneh.badii at gmail.com>
wrote:

> 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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