[bc-gnso] FILED: comment on Translation and Transliteration of Contact Information PDP Initial Report

Steve DelBianco sdelbianco at netchoice.org
Sun Feb 1 18:11:31 UTC 2015

We filed our BC comment today on Translation and Transliteration of Contact Information PDP Initial Report. ( attached  and link<http://www.bizconst.org/wp-content/uploads/2015/02/BC-comment-on-translation-transliteration-of-contact-data-PDP-initial-report.pdf>)

Hearing no guidance on the comments and questions in the draft circulated last week, I used my judgement to resolve things.

Thanks again to Susan Kawaguchi, Ellen Blackler, Steve Coates, and Tim Chen.

From: Steve DelBianco <sdelbianco at netchoice.org<mailto:sdelbianco at netchoice.org>>
Date: Wednesday, January 28, 2015 at 3:22 PM
To: BC Private <bc-private at icann.org<mailto:bc-private at icann.org>>
Cc: "Blackler, Ellen M." <Ellen.M.Blackler at disney.com<mailto:Ellen.M.Blackler at disney.com>>, Tim Chen <tim at domaintools.com<mailto:tim at domaintools.com>>, Stephen Coates <scoates at twitter.com<mailto:scoates at twitter.com>>, Susan Kawaguchi <skawaguchi at fb.com<mailto:skawaguchi at fb.com>>
Subject: FOR FINAL REVIEW: draft 3 of BC comments on translation/transliteration of WHOIS contact data

The attached comment is for FINAL REVIEW by BC members by 31-Jan, so we can submit by 1-Feb deadline.

As discussed on last week’s BC call, ICANN seeks comment on a PDP initial report onTranslation/transliteration of contact data (<https://www.icann.org/public-comments/transliteration-contact-initial-2014-12-16-en%20%20
<https://www.icann.org/public-comments/transliteration-contact-initial-2014-12-16-en>link<https://www.icann.org/public-comments/transliteration-contact-initial-2014-12-16-en> )
Charter question 1 asks us for arguments for/against translating contact information to a single common language or transliterating contact information to a single common script.

Charter question 2 generated 6 preliminary recommendations, and the BC could comment on each of those.

Susan Kawaguchi developed a first draft (while she was en-route to Antarctica).

Ellen Blackler, Steve Coates, and Tim Chen made edits, and inserted questions/comments that we need to address.

Looking for advice from anyone familiar with WHOIS data in non-English and/or non-Latin scripts.

Also, please consider the BC’s prior positions on internationalized registration data (at bottom of this email)

Don’t worry about formatting — I’ll take care of that.


For reference, here are prior BC positions/statements regarding internationalized WHOIS contact data:

Jun-2014 comment supporting proposal of WG on Internationalized Registration Data (link<https://www.icann.org/public-comments/transliteration-contact-initial-2014-12-16-en>), Including:

-The BC recommends the use of free-form text for all name and address fields.  Specifically we support "Proposal 3" for free-form text in the address fields.  Applying a different standard for
address fields, in the broader workflow of a registrant typing in their identity data, is cumbersome and unnecessary.

-To balance the needs of domain name owners, registrars, and users of Whois, It is important that non-ASCII character sets are supported  but not required. Per the Whois Accuracy Specification,
phone numbers and e-mail address formats should still be validated.

-The BC supports localizing data labels based upon registrant location, but it is important that standard US-ASCII data labels still also appear.

Mar-2014 comment on status update from Expert Working Group (EWG) on directory services  (link<http://www.bizconst.org/wp-content/uploads/2014/07/BC-Comments-Status-Report-from-EWG-on-gTLD-Directory-Services-FINAL.pdf>).   Nothing specific on internationalized data, but a good statement on centralized data services.

Jun-2012 comment on WHIS Policy Review Team final report (link<http://www.bizconst.org/wp-content/uploads/2014/06/BC-on-WHOIS-RT-Final-Report.pdf>), including this:

12. Internationalized Registration Data

The BC agrees that the ICANN Community should task a working group within six months of publication to determine appropriate internationalized domains name registration data requirements.

The BC believes that this defining these standards requires special expertise and is not well-suited to a PDP.

13. Internationalized Registration Data Agreements

The BC agrees that the final data model and services should be incorporated and reflected in Registry and Registrar agreements within 6 months of Board adoption. If these new requirements cannot
be finalized in time for the next versions of Registry and Registrar agreements, then an explicit placeholder should be implemented. For existing agreements, the new provisions should be incorporated at the time of renewal.

14. Registration Data Accuracy in Local Languages

The BC agrees that requirements for registration data accuracy and availability in local languages should be finalized along with efforts on internationalization of registration data.

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