[NCSG-PC] Public comment on spec

[Tapani Tarvainen]

Looks good to me. I would like to suggest one minor change:

in III 2., after "particularly those from the Global South"

add " and speakers of small minority languages".

Not critical, I would support it either way, but I'm hoping
to get some Sámi people interested...

Tapani

On Tue, Jan 27, 2026 at 10:23:11AM -0500, farzaneh badii via NCSG-PC (ncsg-pc at lists.ncsg.is) wrote:
> 
> 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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-- 
Tapani Tarvainen