[gnso-contactinfo-pdp-wg] Wednesday 12 November 23:59 UTC soft deadline for comments

Tue Nov 11 11:19:58 UTC 2014

Dear Chris

Thank you for this timely reminder.  Over the past few days, I have been
gathering input from colleagues in the Registrar Stakeholder group.  There
was a rich discussion on the list, with many participants.  These are less
comments on the paper itself than contributions to the general discussion
of the issues.

Here is a synthesis of the comments. I hope that they will be useful in
cross-checking against the *"arguments opposing mandatory transformation"
on pages 11-12:*

1. *Costs*:  This proposal essentially externalises translation costs from
LEA/IP to Registrars, and none of the commentators were convinced that the
costs for contracted parties are justified by benefits to others.  Those
requesting the data can pay for the translation.

2. *Scale*:  Why translate/transliterate all WHOIS data, rather than simply
those names that are of interest on-the-fly?  Status quo is several orders
of magnitude more efficient

3. *Accuracy and responsibility*: If the premise of  WHOIS data is that it
is provided (and declared accurate) by the Registrant, then who accepts
responsibility if Registrars are required to alter that data? How would the
proposals impact whois data accuracy complaints and whois verification
requirements?

4: *Data integrity*: The whois should be displaying what the client
entered.   Our trying to interpret that only leads to more data errors, and
less accurate data. If we change what the client enters it will only lead
to errors:

a.       Will there be rules on how transliterate non-ascii characters so
that it can be done programmatically? Is there some standard system to be
used, or are we all just counting on Google Translate?

b.       If human judgment is required, who is responsible for doing it?

c.       If the registrant is responsible, what if they do not know what it
should be?

d.       What if a third-party disagrees with the accuracy of a
transliteration?

e.       Is the registrant’s consent required before a transliteration is
published in the whois?

f.       Can a registrant withhold consent?

g.       What if a registrant wants to change an “approved” transliteration?

h.       Is a whois verification required every time one of these
transliterated fields are updated?

i.    Where does the requirement for data transformation end? Could Chinese
LEA require a contracted party to translate/transliterate existing English
contact details into Mandarin? Or, what if the original registration was in
a third language/script (Russian Cyrillic), would that skip English and go
directly to Chinese?
5.  *Compliance: "who will and how will this be policed?”*  If ICANN are
making cutbacks in their budget, how are they going to afford the human
resources to check every Whois transliteration is correct? It doesn’t make
much operational sense, and will likely end up with the registrant paying
higher fees for something that they never asked for.

6. *Internationalisation:* The concept starts to erode the “my language, my
Internet” / IDN principle of ICANN, by compelling the use of
English/Latin/ASCII by people and locations not using those language/script
combinations.  One commentator put it as "Sadly, it is North American
thinking I suspect. 'We must translate everything into English'.

7: *Competition:* If a contracted party does not want to support a language
that should be their prerogative. They can turn away business if they
decide that they won’t be able to service that customer appropriately.

---------------

*General comments*

Taking into account the above input, I have the following observations to
make on the draft paper.

First, thank you Chris and the ICANN team for your work in the unenviable
task of fairly summarising the arguments on both sides.  I appreciate that
it is an important step in the process to try and understand the arguments
on both sides.

A general point: I have no sense from the paper, or from the discussions in
the group, of the scale of the problem we are addressing here.  Do we have
any stats for the following:

(1) a breakdown of WHOIS data by country of registrant - and can we infer
what language WHOIS data is likely to be in?  The nearest I can get to is
this map from OII which shows the predominance of Latin script / English
language countries in the current domain market (
http://geography.oii.ox.ac.uk/?page=geography-of-top-level-domain-names) .
However, if you look at growth potential, clearly that is not the case.
And IDN registrations by country show a different pattern (see page 17 at
http://www.eurid.eu/files/publ/IDNWorldReport2014_Interactive.pdf)

(2) an estimate of what is likely to be the language of WHOIS data if
multiple languages were enabled in these fields.  For example, we could
perhaps draw some inferences from the IDN registrations in ASCII TLDs.
Approximately 1% of .com and .net registrations are IDNs, and the majority
of those are Latin script.  This may not be representative in that the
Latin script ending for .com is more likely to be attractive to Latin
script IDNs than, say, right to left scripts or pictograms.  There are
currently just shy of 900,000 Russian ccTLD IDNs.  Of these over 800,000
has a registrant based in Russia, and uptake in other countries is low
(even former Soviet Union).  See
http://statdom.ru/tld/%D1%80%D1%84/report/summary/. There are approximately
12,000 IDNs in Arabic script ccTLDs.  Uptake of IDN new gTLDs has been
fairly limited.  I don't think that anyone is claiming that the IDN market
has even nearly fulfilled its market potential, but can we have some
statement of the scale of the problem?

(3) Do we have a sense of how many WHOIS look-ups are performed by law
enforcement and IP interests, what percentage that represents of all WHOIS
look ups, and how many prove to be problematic in terms of language of
contact?  On the other hand, what problems are currently created by not
having the ability to record contact details in the script of the domain
name (eg for IDNs)?

(4) There have been a number of studies on different aspects of WHOIS data
in the last couple of years - do any of these help to guide us?

*Specific comments*

Page 11 - as you say there is disagreement on "ease" of search.  If you're
English mother tongue, then it might be "easier" to understand the output
of a search, but any string is searchable, and you can interpret the search
results whatever their script/language.

I find the first bullet point unconvincing - it's like saying "why doesn't
everyone just learn English?  It's such a mess having all these languages"

On the second bullet point, p11 - I appreciate that a counter argument is
stated to the "transformation will to some extent facilitate communication"
argument.  The communication argument is a difficult one.  On one level -
as demonstrated within this working group and many others - we default to
English in order to communicate with one another across different
languages.  However, this is also (to some extent) a factor that deters
input from those who are not confident in English as a second language -
who may be able to give valuable insights into the debate.  I believe that
this is captured in "to some extent" but would welcome more acknowledgement
that this cuts both ways.

The third bullet point does not explain why it is also necessary to
transliterate/translate *all* data for this benefit to be felt. We need
some consideration of proportionality here.

Fourth bullet - define "least translatable" - for whom? Is this truly posed
as a barrier to law enforcement and others?

To balance the "cyberflight" argument in the fourth bullet point, could we
also point out that in general people tend to register and host locally.
This is perhaps a surprising phenomenon given the strength of some
registrars internationally.  For example, on page 5 at
http://www.eurid.eu/files/publ/IDNWorldReport2014_Interactive.pdf) we have
an analysis of country of hosting for gTLD IDNs plus .eu IDNs.  This was
done based on the IP ranges associated with the domain names.  You can see
that countries and regions with strong international registrars (eg North
America, UK) don't really show any "winner" script.  In contrast, Chinese
script, Cyrillic, Han (plus Katakana, Hiragana), Thai, Hangul, Arabic
script domains tend to be hosted in countries where associated languages
are spoken.

Could I also add that you can see within large IDN namespaces which offer
multiple scripts (eg .com and .net) that registrations cluster strongly
around popular scripts.  There are very small numbers indeed outside of
them.  I can produce some more analysis on that point if people like.

I hope these inputs are helpful to the working group in its deliberations,
and I look forward to joining the discussions.

Best wishes,

Emily

On 11 November 2014 09:26, Dillon, Chris <c.dillon at ucl.ac.uk> wrote:

>  Dear colleagues,
>
>
>
> Just a reminder about tomorrow’s deadline for comments.
>
>
>
> Regards,
>
>
>
> Chris.
>
> --
>
> Research Associate in Linguistic Computing, Centre for Digital Humanities,
> UCL, Gower St, London WC1E 6BT Tel +44 20 7679 1599 (int 31599)
> www.ucl.ac.uk/dis/people/chrisdillon
>
>
>
> *From:* owner-gnso-contactinfo-pdp-wg at icann.org [mailto:
> owner-gnso-contactinfo-pdp-wg at icann.org] *On Behalf Of *Lars Hoffmann
> *Sent:* 07 November 2014 12:35
> *To:* gnso-contactinfo-pdp-wg at icann.org
> *Subject:* [gnso-contactinfo-pdp-wg] soft DEADLINE
> *Importance:* High
>
>
>
> Dear all,
>
> In order to move our effort forward as smoothly as possible, we suggest
> that in preparation for next week’s call to gather as many comments as
> possible on the latest version of the draft initial report (attached).
>
>
>
> Please provide your feedback by Wednesday 12 November 23:59 UTC – *if you
> don’t provide feedback we will assume that you are content with the report
> as it stands. *If you need more time, please let us know.
>
>
>
> If you do provide feedback, please do so in *track changes* and send it
> back to the list or to lars.hoffmann at icann.org – so that we can collect
> all comments and discuss a * collated version* on next week’s call.
>
>
>
> If you have missed yesterday’s call, you can listen to the  MP3
> <http://audio.icann.org/gnso/gnso-transliteration-contact-20141106-en.mp3> or
> read the Transcript
> <http://gnso.icann.org/en/meetings/transcript-transliteration-contact-06nov14-en.pdf> as
> Chris gave some very useful background information/explanations to the
> latest draft. Please note that there is clean version attached, a red-line
> one should be in your inbox (sent by Chris earlier this week).
>
>
>
> Looking forward to hearing back from you – have a great weekend and best
> wishes,
>
> Lars
>
>
>
>
>
>
>
>
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>

-- 

Emily Taylor

*MA(Cantab), MBA*
Director

*Netistrar Ltd *- Domain Names at Trade Prices
W: http://www.netistrar.com | M: 07540 049322 | T: 01283 617808

Repton House, Bretby Business Park, Bretby, Derbyshire, DE15 0YZ
Registered in England and Wales No. 08735583. VAT No. 190062332
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