[Idngwg] [Ext] haven't received any response from you

Tan Tanaka, Dennis dtantanaka at verisign.com
Sun Aug 19 02:26:04 UTC 2018


Dear all,

I apologize for coming late to this (I was off for a few weeks due to holidays)

I agree with Kal’s view point, so support using that as a next response to Yoshitaka-san.

Dennis

Sent from my iPhone

> On Aug 18, 2018, at 2:49 AM, Sarmad Hussain <sarmad.hussain at icann.org> wrote:
> 
> Dear All,
> 
> There is no further discussion on this.  Should I convert the following text by Kal in a response and share back with all of you for review.  Do we need to add any further discussion?
> 
>> While it is certainly worth hearing from JPRS and their perspective on > the guidelines, if the guidelines are unlikely to change until another > draft is developed well into the future, we should be very clear about > that fact to Yoshitaka and anyone else corresponding with the WG.
>> 
>> As for Yoshitaka's points, my preference is always to err towards 
>> permissible guidelines and to let registries control their own fate. I > think the guidelines do allow this. The guidelines say that exceptions > to the requirement should be covered by IDN policies, which parallels 
>> Yoshitaka's suggestion that confusable registrations could be resolved > via DRP (I presume he is using the common acronym for Dispute 
>> Resolution Policy). In my opinion the guidelines do not prevent JPRS 
>> from doing exactly as they wish.
> 
> Regards,
> Sarmad
> 
> -----Original Message-----
> From: Idngwg <idngwg-bounces at icann.org> On Behalf Of Kal Feher
> Sent: Saturday, August 18, 2018 6:02 AM
> To: idngwg at icann.org
> Subject: Re: [Idngwg] [Ext] haven't received any response from you
> 
> I think we still owe Yoshitaka a reply, unless one has gone out that I have missed.
> 
> 
>> On 1/8/18 9:44 pm, Kal Feher wrote:
>> I'd like to understand what exactly this group can and should do going > forward with the guidelines at this stage?
>> 
>> While it is certainly worth hearing from JPRS and their perspective on > the guidelines, if the guidelines are unlikely to change until another > draft is developed well into the future, we should be very clear about > that fact to Yoshitaka and anyone else corresponding with the WG.
>> 
>> As for Yoshitaka's points, my preference is always to err towards 
>> permissible guidelines and to let registries control their own fate. I > think the guidelines do allow this. The guidelines say that exceptions > to the requirement should be covered by IDN policies, which parallels 
>> Yoshitaka's suggestion that confusable registrations could be resolved > via DRP (I presume he is using the common acronym for Dispute 
>> Resolution Policy). In my opinion the guidelines do not prevent JPRS 
>> from doing exactly as they wish.
>> 
>> Kal
>> 
>> 
>>> On 31/7/18 10:03 pm, Mats Dufberg wrote:
>>> [Internal message, Yoshitaka Okuno not included.]
>>> 
>>> After reading the message Yoshitaka Okuno(1) I have the following 
>>> reflections and questions:
>>> 
>>> He states regarding example in 2 below:
>>> 
>>> "These may be regarded as confusable strings by some people."
>>> 
>>> Does he then mean people outside the Japanese community?
>>> 
>>> "But these consist of totally different characters with different 
>>> reading and meaning, and each of them exists in reality. We think 
>>> both words should be allowed to be registered as domain name labels.
>>>     Those words live in Japanese real life with no confusion."
>>> 
>>> Does he mean that people from the Japanese community will have no 
>>> problem to differentiate between the two phrases? Or does he mean 
>>> that the two phrases are usually used in two different contexts so 
>>> that no real confusion happens?
>>> 
>>> In whose eyes should the "visual similarity" sit?
>>> 
>>> 
>>> 
>>> Mats
>>> 
>>> (1) As far as I can see, Yoshitaka is a male's name and therefore 
>>> "he", "his".
>>> 
>>> ---
>>> Mats Dufberg
>>> DNS Specialist, IIS
>>> Mobile: +46 73 065 3899
>>> https://www.iis.se/en/
>>> 
>>> -----Original Message-----
>>> From: Idngwg <idngwg-bounces at icann.org> on behalf of 
>>> "yoshitaka at jprs.co.jp" <yoshitaka at jprs.co.jp>
>>> Date: Tuesday, 31 July 2018 at 09:27
>>> To: Sarmad Hussain <sarmad.hussain at icann.org>, idngwg 
>>> <idngwg at icann.org>
>>> Cc: "yoshitaka at jprs.co.jp" <yoshitaka at jprs.co.jp>
>>> Subject: Re: [Idngwg] [Ext] haven't received any response from you
>>> 
>>>     Dear IDNGWG and Sarmad Hussain,
>>>          Thank you for your confirmation.
>>>     We feel very disappointed that our opinion is not adopted.
>>>          We still cannot understand the basic concept of IDN 
>>> Guidelines.
>>>          To understand your concept, we would like to show you some 
>>> typical
>>>     cases of Japanese language words as follows.
>>>          We would appreciate if IDNGWG could tell us their opinion 
>>> for each.
>>> 
>>> ---------------------------------------------------------------------
>>> -
>>>     1. should confusable characters be forced out of repertoire?
>>>          In defining a set of characters that can be used in 
>>> Japanese labels,
>>>     we think that it is not appropriate to prohibit other characters >> to
>>>     be used, leaving only one character, just because certain 
>>> characters
>>>     are visually confusable to each other. That would inhibit 
>>> natural
>>>     expressions or daily-used input method.
>>>          As we explained over and over again, Hiragana, Katakana and >> Kanji
>>>     characters can be mixed in an arbitrary order in Japanese words.
>>>     And daily-used computer input method supports such typing.
>>>          This illustrates the same situation where "l"/"O" is forced >> out of
>>>     repertoire just because "1"/"0" is visually confusable with 
>>> "l"/"O".
>>>     In this case "fortune100.TLD" cannot be an applied-for label and >> the
>>>     applicant must apply for "fortuneloo.TLD" (el-ou-ou) instead of
>>>     "fortune100.TLD". If ASCII labels follow the concept of 
>>> guidelines,
>>>     "1" and "0" are not allowed to be used in any labels at all.
>>>          Therefore, our answer to the original question "should 
>>> confusable
>>>     characters be forced out of repertoire?" is "No".
>>>               Question for IDNGWG;
>>>     Do you have any differnet opinions about this issues?
>>> 
>>> ---------------------------------------------------------------------
>>> -
>>>     2. should confusable labels be blocked?
>>>          Please see the following examples.
>>>              "ハニー" (U+30CF, U+30CB, U+30FC) means "honey"
>>>              "八二一" (U+516B, U+4E8C, U+4E00) means group name of 
>>> Japanese
>>>         photographers "hani hajime"
>>>          These may be regarded as confusable strings by some people.
>>>          But these consist of totally different characters with 
>>> different reading
>>>     and meaning, and each of them exists in reality. We think both 
>>> words
>>>     should be allowed to be registered as domain name labels.
>>>          Those words live in Japanese real life with no confusion.
>>>          If there should be any problems on their use, they should 
>>> be resolved
>>>     using DRP.
>>>          Therefore, our answer to the original question "should 
>>> confusable labels
>>>     be blocked?" is "No".
>>>               Questions for IDNGWG;
>>>     Do you think that only one of them is allowed to be registered 
>>> in the above
>>>     example? And what is the reason and/or tangible ground of your 
>>> opinion?
>>> 
>>> ---------------------------------------------------------------------
>>>          Best Regards,
>>>     ----
>>>     Yoshitaka Okuno
>>>     Manager, Services Development Department Japan Registry Services >> Co., Ltd.
>>>               On Mon, 9 Jul 2018 22:21:36 +0000
>>>     Sarmad Hussain <sarmad.hussain at icann.org> wrote:
>>>> Dear Yoshitaka Okuno,
>>>> 
>>>> I apologize for the delay in responding, as I have been 
>>> traveling.
>>>> 
>>>> Please find below the response from the IDN Guidelines WG to 
>>> your follow-up
>>>> query.
>>>> 
>>>> Please separately let me know if you have a query or comment 
>>> for the
>>>> integration panel in the context of Japanese proposal for the 
>>> Root Zone LGR.
>>>> 
>>>> Regards
>>>> Sarmad
>>>> 
>>>> 
>>>> -----------
>>>> Dear Yoshitaka Okuno,
>>>> 
>>>> The IDN Guidelines WG had discussed the case of Japanese 
>>> writing system at
>>>> multiple meetings based on feedback received from JPRS.
>>>> 
>>>> Kindly note that based on the definition of scripts by the 
>>> Unicode standard,
>>>> Japanese writing system mixes Hiragana, Katakana and Kanji
>>> (Han) scripts.
>>>> Guideline 15 puts constraints on mixing scripts in general. 
>>> But associated
>>>> Additional Notes have been added to note that Hiragana, 
>>> Katakana and Kanji
>>>> (Han) scripts along with ASCII are allowed to be mixed for the >> Japanese
>>>> writing system.
>>>> 
>>>> Guideline 16 is specifically applicable to all the script 
>>> mixing cases
>>>> allowed in Guideline 15.  Therefore, Guideline 16 will be 
>>> applicable to the
>>>> Japanese writing system as well.
>>>> 
>>>> Regards,
>>>> IDN Guidelines WG
>>>> 
>>>> 
>>>> 
>>>> -----Original Message-----
>>>> From: yoshitaka at jprs.co.jp [mailto:yoshitaka at jprs.co.jp]
>>>> Sent: Wednesday, June 13, 2018 6:06 AM
>>>> To: Sarmad Hussain <sarmad.hussain at icann.org>
>>>> Cc: yoshitaka at jprs.co.jp; Pitinan Kooarmornpatana 
>>> <pitinan.koo at icann.org>;
>>>> idngwg at icann.org
>>>> Subject: RE: [Ext] haven't received any response from you
>>>> 
>>>> Dear IDNGWG and Sarmad Hussain,
>>>> 
>>>> I apologize for this delayed response due to false positive of >> my SPAM
>>>> filter.
>>>> 
>>>> Thank you for sharing our comments with IDNGWG members.
>>>> 
>>>> We hope that the consequence is clearly described as follows 
>>> in item V of
>>>> "2.8 Additional Notes" to make readers unmistakably understand >> the
>>>> guidelines.
>>>> 
>>>> ===
>>>> Guideline 15:
>>>> For example, Japanese language normally mixes Hiragana, 
>>> Katakana and Han
>>>> scripts. Therefore, Japanese labels can be mixed strings of 
>>> Hiragana,
>>>> Katakana and Han characters, and shall be treated in the same 
>>> way as in a
>>>> single Unicode script. Also, for Chinese, ....
>>>> ===
>>>> 
>>>> We should not treat "mixing of Hiragana, Katakana and Han" and >> "mixing of
>>>> different language scripts" in the same rank, and we should 
>>> clearly state
>>>> this concept in the guidelines.
>>>> 
>>>> We hope that you would share our additional comment as above 
>>> with
>>>> Integration Panel members.
>>>> 
>>>> Thanks and Regards,
>>>> 
>>>> Yoshitaka Okuno
>>>> Manager, Services Development Department Japan Registry 
>>> Services Co., Ltd.
>>>> 
>>>> PS.
>>>> We still have a strong view that visual similarity should be 
>>> dealt with in
>>>> applications or DRP, not in domain name registration, if such 
>>> treatment is
>>>> needed. We hope this view will be communicated more openly later.
>>>> 
>>>> Best Regards,
>>>> ----
>>>> Yoshitaka Okuno
>>>> Manager, Services Development Department Japan Registry 
>>> Services Co., Ltd.
>>>> 
>>>> 
>>>> On Mon, 28 May 2018 05:26:17 +0000
>>>> Sarmad Hussain <sarmad.hussain at icann.org> wrote:
>>>> 
>>>>> Dear Yoshitaka Okuno,
>>>>> 
>>>>> Thank you for your response.
>>>>> 
>>>>> This is to acknowledge its receipt and to confirm that your 
>>> response
>>>>> below has been shared with the IDNGWG members.
>>>>> 
>>>>> Regards,
>>>>> Sarmad
>>>>> 
>>>>> -----Original Message-----
>>>>> From: yoshitaka at jprs.co.jp [mailto:yoshitaka at jprs.co.jp]
>>>>> Sent: Monday, May 28, 2018 9:06 AM
>>>>> To: Sarmad Hussain <sarmad.hussain at icann.org>
>>>>> Cc: yoshitaka at jprs.co.jp; Pitinan Kooarmornpatana
>>>>> <pitinan.koo at icann.org>; idngwg at icann.org
>>>>> Subject: RE: [Ext] haven't received any response from you
>>>>> 
>>>>> Dear IDNGWG and Sarmad Hussain,
>>>>> 
>>>>> Thank you for your response.
>>>>> 
>>>>> We summarized our understanding as below.
>>>>> 
>>>>> Should this mail doesn't reach IDNGWG, I'd appreciate it if 
>>> Mr. Sarmad
>>>>> could forward it to IDNGWG.
>>>>> 
>>>>> We have recognized that IDNGWG added Additional Note V and 
>>> VI to the
>>>>> Guideline as a result of discussion on our comments.
>>>>> 
>>>>> We have understood that Japanese language shall not be 
>>> considered as
>>>>> "mixing of Unicode scripts" written in Guideline #16.
>>>>> 
>>>>> Thanks again for your assistance.
>>>>> 
>>>>> Best Regards,
>>>>> ----
>>>>> Yoshitaka Okuno
>>>>> Manager, Services Development Department Japan Registry 
>>> Services Co., Ltd.
>>>>> 
>>>>> 
>>>>> 
>>>>> On Fri, 18 May 2018 06:04:54 +0000
>>>>> Sarmad Hussain <sarmad.hussain at icann.org> wrote:
>>>>> 
>>>>>> Dear Yoshitaka Okuno,
>>>>>> 
>>>>>> Please find below the response by the IDN Guidelines 
>>> Working Group
>>>>> (IDNGWG).
>>>>>> 
>>>>>> Regards,
>>>>>> Sarmad
>>>>>> =============
>>>>>> 
>>>>>> Yoshitaka Okuno
>>>>>> Manager, Services Development Department Japan Registry 
>>> Services Co.,
>>>> Ltd.
>>>>>> 
>>>>>> Dear Yoshitaka Okuno,
>>>>>> 
>>>>>> Thank you for your emails.  The IDN Guidelines WG 
>>> appreciates the
>>>>>> continued input from JPRS, and had discussed the input at 
>>> multiple
>>>>>> WG meetings and the means to address it.
>>>>>> 
>>>>>> Please note that the Guidelines 15 and 16 in the proposed 
>>> version
>>>>>> 4.0 are not new.  These are a part of the existing version
>>> 3.0 of
>>>>>> the IDN Guidelines, which are currently implemented (see
>>>>>> 
>>> https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_r
>>>>>> es
>>>>>> 
>>>>> 
>>> ources_pages_idn-2Dguidelines-2D2011-2D09-2D02-2Den&d=DwICJg&c=FmY1u3>> P
>>>>> Jp6wrc
>>>>> 
>>> rwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=KTETvEaGPwPcawI-QmNa-kiv-ZBvdgyyLm-m
>>> x
>>>>> d028M4
>>>>> 
>>> &m=KR3mHCS8MRtbT2mH1CivMpm_Vg71we-wvho7cqN5Z9Q&s=FeWKN256bvrq6yzR-dhE>> D
>>>>> -qNb7W nq8_cy1tkQv6CwGA&e=).  The existing guideline states:
>>>>>> 
>>>>>> 5.            “All code points in a single label will be 
>>> taken from the
>>>>>> same script as determined by the Unicode Standard Annex
>>> #24: Script
>>>>>> Names
>>>>>> 
>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.unicode.org
>>>>>> _r
>>>>>> 
>>> eports_tr24&d=DwICJg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r
>>>>>> =K
>>>>>> 
>>> TETvEaGPwPcawI-QmNa-kiv-ZBvdgyyLm-mxd028M4&m=KR3mHCS8MRtbT2mH1CivMpm
>>>>>> _V
>>>>>> 
>>> g71we-wvho7cqN5Z9Q&s=wkkgI6r04K42Ol_7w4Xo__C0IXBtXIKYZmKGmP4teq0&e=>.>>      > > > Exceptions to this guideline are permissible for languages >> with
>>>>> established orthographies and conventions that require the 
>>> commingled
>>>>> use of multiple scripts. Even in the case of this exception, >> visually
>>>>> confusable characters from different scripts will not be 
>>> allowed to
>>>>> co-exist in a single set of permissible code points unless a
>>>>> corresponding policy and character table is clearly defined."
>>>>>> 
>>>>>> For more clarity, in the proposed version 4.0 this 
>>> guideline has
>>>>>> been divided into two parts.  Guideline 15 addresses the 
>>> first part,
>>>>>> while Guideline 16 covers the second part of the existing
>>> guideline:
>>>>>> 
>>>>>> 15.          All code points in a single IDN label must be >> taken from
>>>> the
>>>>>> same Unicode script as determined by the Unicode Standard 
>>> Annex #24:
>>>>>> Unicode Script Property
>>>>>> 
>>> (https://urldefense.proofpoint.com/v2/url?u=http-3A__www.unicode.org
>>>>>> _r
>>>>>> 
>>>>> 
>>> eports_tr24&d=DwICJg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=>> K
>>>>> TETvEa
>>>>> 
>>> GPwPcawI-QmNa-kiv-ZBvdgyyLm-mxd028M4&m=KR3mHCS8MRtbT2mH1CivMpm_Vg71we
>>> -
>>>>> wvho7c
>>> qN5Z9Q&s=wkkgI6r04K42Ol_7w4Xo__C0IXBtXIKYZmKGmP4teq0&e=).
>>>>> Exceptions to this guideline are permissible for languages 
>>> with
>>>>> established orthographies and conventions that require the 
>>> commingled
>>>>> use of multiple Unicode scripts.
>>>>>> Also see Additional Notes V and VI.
>>>>>> 
>>>>>> 16.          In the case of any exceptions made allowing 
>>> mixing of
>>>> Unicode
>>>>>> scripts, visually confusable characters from different 
>>> scripts must
>>>>>> not be allowed to co-exist in a single set of permissible 
>>> code
>>>>>> points unless a corresponding IDN policy and IDN Table is 
>>> clearly
>>>>>> defined to minimize confusion between domain names.  Also 
>>> see Additional
>>>> Note IV.
>>>>>> 
>>>>>> Considering the JPRS input and additional discussion by 
>>> its members,
>>>>>> the IDN Guidelines WG has made some finer clarifications 
>>> without
>>>>>> changing the intention of the original guideline in 
>>> version 3.0, as
>>>>>> per the details
>>>>>> below:
>>>>>> 
>>>>>> 1.            For referring to Japanese case and other 
>>> cases, the WG
>>>>>> discussed that changes should be made in Guideline 15 and 
>>> not in
>>>>>> Guideline 16.
>>>>>> 2.            The WG considered that the use of “script”
>>> may be
>>>>> ambiguous
>>>>>> and so changed the text to refer explicitly to “Unicode 
>>> script” as
>>>>>> defined in the Unicode script property.  This was implied 
>>> in the
>>>>>> original ver. 3.0 of the Guidelines, which had referred to >> UTR 24.
>>>>>> 3.            In the context of “Unicode script”, Japanese 
>>> writing
>>>>> system
>>>>>> uses Hiragana, Katakana and Han. Therefore, based on JPRS 
>>> input, the
>>>>>> WG agreed to qualify Japanese writing system as a case 
>>> which mixes
>>>>>> "Unicode scripts" and therefore should be allowed by 
>>> default.  As
>>>>>> the guidelines themselves were intended to be generic, the >> WG agreed
>>>>>> that this be done as an Additional Note and not in the 
>>> text of the
>>>> guideline.
>>>>>> 4.            Additional Note V was added to state that 
>>> Japanese is a
>>>>> known
>>>>>> case where Hiragana, Katakana and Han scripts are mixed. 
>>> It also notes
>>>>>> that Chinese, Japanese and Korean IDN tables also mix 
>>> “a-z” ASCII.
>>>>>> Additional Note VI allows additional letters like digits 
>>> and hyphen
>>>>>> to be mixed in scripts, where relevant.  Therefore, 
>>> cumulatively
>>>>>> these notes allow for labels like "jpドメイン名の登録".  So the
>>>> Additional
>>>>>> Notes
>>>>> V
>>>>>> and VI cover the concerns raised by JPRS to pre-qualify 
>>> "Unicode
>>>>>> script"-mixing in Japanese writing system.
>>>>>> 
>>>>>> Please also note that there are two separate guidelines 
>>> which call
>>>>>> for addressing similarity and confusability - no. 14 
>>> specifically
>>>>>> for within-script cases and no. 16 specifically for 
>>> allowed
>>>>>> cross-script
>>>>> cases.
>>>>>> Therefore, no. 16 was not altered to be more generic. Both >> these
>>>>>> guidelines point to Additional Note IV, which suggest 
>>> additional
>>>>>> mechanisms for this purpose.
>>>>>> 
>>>>>> We hope this clarifies the motivations of the WG on how it >> has tried
>>>>>> to address the input from JPRS.  Please let us know if you >> have any
>>>>>> further input or concerns.
>>>>>> 
>>>>>> Regards,
>>>>>> IDN Guidelines WG
>>>>>> 
>>>>>> 
>>>>>> -----Original Message-----
>>>>>> From: yoshitaka at jprs.co.jp [mailto:yoshitaka at jprs.co.jp]
>>>>>> Sent: Friday, May 11, 2018 2:49 PM
>>>>>> To: Mats Dufberg <mats.dufberg at iis.se>
>>>>>> Cc: Sarmad Hussain <sarmad.hussain at icann.org>; Pitinan
>>>>>> Kooarmornpatana <pitinan.koo at icann.org>
>>>>>> Subject: [Ext] haven't received any response from you
>>>>>> 
>>>>>> Dear IDN guidelines WG Chair,
>>>>>> (CC: Sarmad、Pitinan)
>>>>>> 
>>>>>> On 30 March, I sent you our proposed change on the IDN
>>>>>> implementation guidelines document, following the 
>>> suggestion made in
>>>>>> the WG public meeting in San Juan on 12 March (pasted 
>>> below). For
>>>>>> these one and half months, I have not received any 
>>> response to that from
>>>> you.
>>>>>> 
>>>>>> Today, I happened to find that "Final Proposed Draft v.
>>> 4.0 of the
>>>>>> IDN Guidelines"
>>>>>> 
>>> https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_n
>>>>>> ew
>>>>>> s_anno
>>>>>> 
>>> uncement-2D2018-2D05-2D10-2Den&d=DwICJg&c=FmY1u3PJp6wrcrwll3mSVzgfkb
>>>>>> PS
>>>>>> S6sJms
>>>>>> 
>>> 7xcl4I5cM&r=KTETvEaGPwPcawI-QmNa-kiv-ZBvdgyyLm-mxd028M4&m=zptC-TxcZW
>>>>>> 1P
>>>>>> mY1jJ5
>>>>>> 
>>> LzXVqPvD3ZlsiKvb4agfECycQ&s=wxk9m-mdZnan6Q2PmV36GLfLEXk6eKFuZRXMIFdZ
>>>>>> Le
>>>>>> g&e=
>>>>>> was published.
>>>>>> 
>>>>>> It was a surprise and disappointing for us to find it 
>>> without prior
>>>>>> correspondence regarding our proposal sent to you on 30 
>>> March.
>>>>>> 
>>>>>> Yoshitaka Okuno
>>>>>> Manager, Services Development Department Japan Registry 
>>> Services Co.,
>>>> Ltd.
>>>>>> 
>>>>>> 
>>>>>> On Fri, 30 Mar 2018 17:40:59 +0900
>>>>>> yoshitaka at jprs.co.jp wrote:
>>>>>>> Dear IDN guidelines working group,
>>>>>>> 
>>>>>>> Please refer to the following comments and proposal.
>>>>>>> The comments and proposal are being sent to you, 
>>> following your
>>>>>>> suggestion made in IDN Guidelines Working Group meeting 
>>> in San Juan.
>>>>>>> 
>>>>>>> In the working group meeting, the essence was orally 
>>> stated by
>>>>>>> Hiro Hotta, JPRS in the meeting room.
>>>>>>> 
>>>>>>> I hope this may be of help to you.
>>>>>>> 
>>>>>>> 
>>>>>>> [Summary]
>>>>>>> 
>>>>>>> 1. As described in current guidelines, the issues of 
>>> visually
>>>> confusable
>>>>>>>   characters are not specific to the cases with 
>>> commingled use of
>>>>>>>   multiple scripts.
>>>>>>> 
>>>>>>>   We believe Japanese domain labels fall on the 
>>> exceptional cases
>>>>>>>   stated in Guideline#15.
>>>>>>>   Kanji, Hiragana, and Katakana scrips are daily used 
>>> in a
>>>>>>>   commingled manner based on established orthographies 
>>> and
>>>>>>>   conventions in Japan. Such comingled use is allowed 
>>> even in
>>>>>>>   single words. This means Japanese people consider the >> collective
>>>>>>>   set of Kanji, Hiragana, and Katakana characters to 
>>> belong to ONE
>>>>>>>   script in constituting Japanese words, just as native >> English
>>>>>>>   writers/readers consider English characters to belong >> to ONE
>>>>>>>   script.
>>>>>>> 
>>>>>>>   Therefore, in the case where comingled use of UNICODE >> scripts is
>>>>>>>   allowed by Guideline#15, restrictions (if any) should >> be the same
>>>>>>>   as in the case of one UNICODE script in constituting 
>>> domain
>>>>>>>   labels.
>>>>>>> 
>>>>>>> 2. In Additional Note IV, the guidelines of visually 
>>> confusable
>>>>>>>   characters are described. We think they are the good 
>>> notes because
>>>>>>>   the issues of visually confusable characters are 
>>> clearly pointed.
>>>>>>> 
>>>>>>>   Taking into account the fact that issues of visually 
>>> confusable
>>>>>>>   characters reside both in the case of a single 
>>> UNICODE script and
>>>>>>>   in the case where comingled UNICODE scripts are 
>>> allowed, we think
>>>>>>>   the sentence "must not be allowed to" is 
>>> overdescribed in
>>>>>>>   guideline#16.
>>>>>>> 
>>>>>>> [Suggestion]
>>>>>>> 
>>>>>>>  We would like to propose as follows.
>>>>>>> 
>>>>>>>  - The guideline#16 is removed from section 2.5.2 and 
>>> is moved to
>>>>>>>    a newly created section between 2.5.2 and 2.5.3. The >> new section
>>>>>>>    is headlined as "2.5.X Visually confusable characters".
>>>>>>> 
>>>>>>>  - The guideline#16 will be modified as follows.
>>>>>>> 
>>>> 
>>> -------------------------------------------------------------------
>>>>>>>    16.
>>>>>>>    Visually confusable characters had better not 
>>> co-exist in a single
>>>>>>>    set of permissible code points. TLD registries 
>>> should clearly
>>>>>>>    define a corresponding policy and IDN Table to 
>>> minimize confusion
>>>>>>>    between domain names. Also see Additional Note IV.
>>>>>>> 
>>>>>>> 
>>> ------------------------------------------------------------------
>>>>>>> -
>>>>>>> 
>>>>>>> Thanks for your consideration.
>>>>>>> ----
>>>>>>> Yoshitaka Okuno
>>>>>>> Manager, Services Development Department Japan Registry 
>>> Services
>>>>>>> Co., Ltd.
>>>>>>> 
>>>>>>> 
>>>>>> 
>>>>>> 
>>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> ------=_NextPart_000_0060_01D3F66E.4DAD12E0
>>>>> Content-Type: application/pkcs7-signature; name="smime.p7s"
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>>> LGQBGRYCZHMxHTAbBgNVBAMTFGFkMS1sYXguZHMuaWNhbm4ub3JnMIIBIjANBgkqhkiG9
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>>>>> G4vyR7
>>>>> 
>>> m182FaFtyt3kbCgzat38XbGtpUkpf/TWmumJUnKODb1Mtt3YB6B5URPGFyIu1aa/o31Wj
>>> K
>>>>> Y/hLGR
>>>>> 
>>> 4a3tNRIpfy7JUnI7SiWfjoeiq2q1xwPCJ+xdfeOwkJEagM5L9BE3jRKGxEve0DLTWvDtJ
>>> 4a3tNRIpfy7JUnI7SiWfjoeiq2q1xwPCJ+Z
>>>>> 4a3tNRIpfy7JUnI7SiWfjoeiq2q1xwPCJ+pMKSdr
>>>>> 
>>> NGPYViHYuRlizbvil6+Jux7kNg9cMxrqZUW7zx6xsBKfmISH/gNZQsSrX9IlRJNVQh/ov
>>> NGPYViHYuRlizbvil6+7
>>>>> NGPYViHYuRlizbvil6+eef7MY
>>>>> 
>>> R98TLnnOpaonPQR54nk2IlABW8ZQjYyCfNftTCyTwVJyL0M05qWJG+b7eQIDAQABo4GRM
>>> R98TLnnOpaonPQR54nk2IlABW8ZQjYyCfNftTCyTwVJyL0M05qWJG+I
>>>>> R98TLnnOpaonPQR54nk2IlABW8ZQjYyCfNftTCyTwVJyL0M05qWJG+GOMBMG
>>>>> 
>>> CSsGAQQBgjcUAgQGHgQAQwBBMA4GA1UdDwEB/wQEAwIBhjAPBgNVHRMBAf8EBTADAQH/M
>>> B
>>>>> 0GA1Ud
>>>>> 
>>> DgQWBBTpKerCBbuXyks/cnl6+luCS7lqhDASBgkrBgEEAYI3FQEEBQIDAQABMCMGCSsGA
>>> Q
>>>>> QBgjcV
>>>>> 
>>> AgQWBBQ7JvikaZYKKTIHybKXhMebCWyPKzANBgkqhkiG9w0BAQUFAAOCAQEADOmrsr5f5
>>> i
>>>>> gaqu9A
>>>>> 
>>> 4YOPskS46dvfemEAWChEjoEAg1kIPWMkJx4hn0wkgd7/QbzCRUxS2iFHWPU+kQUTLKj9G
>>> G
>>>>> iUVdQ6
>>>>> 
>>> YjDg2Qrc6a9F0re7zj/mhqZrSJAbgG0qgRjlKSodltvw74lLpK8BH3hbTuBp3Fcp605zs
>>> G
>>>>> iJHfmc
>>>>> 
>>> B3X25UqJ9QUtc+Pf+49UtLCf3bGzKTvwoGa+UAsioZ55ii2Jqh8JJBf17WqWNioMAxKJR
>>> B3X25UqJ9QUtc+Pf+49UtLCf3bGzKTvwoGa+s
>>>>> B3X25UqJ9QUtc+Pf+49UtLCf3bGzKTvwoGa+rLNiWo
>>>>> 
>>> UwWZiWe5A5o87WCTnRXbC/X1RmlbiyzAWtGThC1dVONa93SxZFZGFeBQD7Np1bhwSFhPc
>>> e
>>>>> qVkyON
>>>>> 
>>> iuPzlS6LSb/0FPi2imPszjCCBwIwggXqoAMCAQICCnVql4YAAQAACR8wDQYJKoZIhvcNA
>>> Q
>>>>> EFBQAw
>>>>> 
>>> XzETMBEGCgmSJomT8ixkARkWA29yZzEVMBMGCgmSJomT8ixkARkWBWljYW5uMRIwEAYKC
>>> Z
>>>>> ImiZPy
>>>>> 
>>> LGQBGRYCZHMxHTAbBgNVBAMTFGFkMS1sYXguZHMuaWNhbm4ub3JnMB4XDTE4MDUwMzIwM
>>> T
>>>>> AzMFoX
>>>>> 
>>> DTIwMDUwMjIwMTAzMFowgZgxEzARBgoJkiaJk/IsZAEZFgNvcmcxFTATBgoJkiaJk/IsZ
>>> A
>>>>> EZFgVp
>>>>> 
>>> Y2FubjESMBAGCgmSJomT8ixkARkWAmRzMRQwEgYDVQQLEwtJQ0FOTi1Vc2VyczEXMBUGA
>>> 1
>>>>> UEAxMO
>>>>> 
>>> U2FybWFkIEh1c3NhaW4xJzAlBgkqhkiG9w0BCQEWGHNhcm1hZC5odXNzYWluQGljYW5uL
>>> m
>>>>> 9yZzCC
>>>>> 
>>> ASIwDQYJKoZIhvcNAQEBBQADggEPADCCAQoCggEBAMeUJZWT2LHkkgUQ3PBYne3/nqJ2Q
>>> 9
>>>>> o0N+41
>>>>> 
>>> SzEall6+A+7o8nU9ZLDgCkCobGmM+kdoEMqRZJ10HeiMDuJxLgEn6kWGXWp8U1vb6qHX8
>>> SzEall6+A+7o8nU9ZLDgCkCobGmM+H
>>>>> SzEall6+A+7o8nU9ZLDgCkCobGmM+SbHkoC
>>>>> 
>>> 0L+PdB6in1CSYw7892ll76dAc/5w1z8PRHXfjcL/+I2YpCO5UCU98Unp2u1mmCXXndmeY
>>> 0L+7
>>>>> 0L+3sZRkY
>>>>> 
>>> HcKuZRaR03hksSGuKgxd+wHStK9woa5R8KQS1Gc6IHRFPJT7G4tR98iqYGqxkxe/itSM2
>>> HcKuZRaR03hksSGuKgxd++
>>>>> HcKuZRaR03hksSGuKgxd+54d/Xr
>>>>> 
>>> 4RSq34jyYCqc690W94Vp2LP69wWOCakCSysUUI3LcFp8urfC5ZQVGRBiqlPNySg4R4okJ
>>> K
>>>>> bKDMil
>>>>> 
>>> EBkCAwEAAaOCA4QwggOAMD0GCSsGAQQBgjcVBwQwMC4GJisGAQQBgjcVCIG6sk2EyMhqg
>>> 6
>>>>> 2TP4eU
>>>>> 
>>> 9FqD+YhuTofryz+Gg5haAgFkAgEHMCkGA1UdJQQiMCAGCisGAQQBgjcKAwQGCCsGAQUFB
>>> 9FqD+YhuTofryz+w
>>>>> 9FqD+YhuTofryz+MEBggr
>>>>> 
>>> BgEFBQcDAjAOBgNVHQ8BAf8EBAMCBaAwNQYJKwYBBAGCNxUKBCgwJjAMBgorBgEEAYI3C
>>> g
>>>>> MEMAoG
>>>>> 
>>> CCsGAQUFBwMEMAoGCCsGAQUFBwMCMIGUBgkqhkiG9w0BCQ8EgYYwgYMwCwYJYIZIAWUDB
>>> A
>>>>> EqMAsG
>>>>> 
>>> CWCGSAFlAwQBLTALBglghkgBZQMEARYwCwYJYIZIAWUDBAEZMAsGCWCGSAFlAwQBAjALB
>>> g
>>>>> lghkgB
>>>>> 
>>> ZQMEAQUwCgYIKoZIhvcNAwcwBwYFKw4DAgcwDgYIKoZIhvcNAwICAgCAMA4GCCqGSIb3D
>>> Q
>>>>> MEAgIC
>>>>> 
>>> ADAdBgNVHQ4EFgQUb9oEypTkHK3ULRCW/C19dwlSCH8wHwYDVR0jBBgwFoAU6SnqwgW7l
>>> 8
>>>>> pLP3J5
>>>>> 
>>> evpbgku5aoQwgdkGA1UdHwSB0TCBzjCBy6CByKCBxYaBwmxkYXA6Ly8vQ049YWQxLWxhe
>>> C
>>>>> 5kcy5p
>>>>> 
>>> Y2Fubi5vcmcoMSksQ049YWQxLWxheCxDTj1DRFAsQ049UHVibGljJTIwS2V5JTIwU2Vyd
>>> m
>>>>> ljZXMs
>>>>> 
>>> Q049U2VydmljZXMsQ049Q29uZmlndXJhdGlvbixEQz1kcyxEQz1pY2FubixEQz1vcmc/Y
>>> 2
>>>>> VydGlm
>>>>> 
>>> aWNhdGVSZXZvY2F0aW9uTGlzdD9iYXNlP29iamVjdENsYXNzPWNSTERpc3RyaWJ1dGlvb
>>> l
>>>>> BvaW50
>>>>> 
>>> MIHKBggrBgEFBQcBAQSBvTCBujCBtwYIKwYBBQUHMAKGgapsZGFwOi8vL0NOPWFkMS1sY
>>> X
>>>>> guZHMu
>>>>> 
>>> aWNhbm4ub3JnLENOPUFJQSxDTj1QdWJsaWMlMjBLZXklMjBTZXJ2aWNlcyxDTj1TZXJ2a
>>> W
>>>>> NlcyxD
>>>>> 
>>> Tj1Db25maWd1cmF0aW9uLERDPWRzLERDPWljYW5uLERDPW9yZz9jQUNlcnRpZmljYXRlP
>>> 2
>>>>> Jhc2U/
>>>>> 
>>> b2JqZWN0Q2xhc3M9Y2VydGlmaWNhdGlvbkF1dGhvcml0eTBNBgNVHREERjBEoCgGCisGA
>>> Q
>>>>> QBgjcU
>>>>> 
>>> AgOgGgwYc2FybWFkLmh1c3NhaW5AaWNhbm4ub3JngRhzYXJtYWQuaHVzc2FpbkBpY2Fub
>>> i
>>>>> 5vcmcw
>>>>> 
>>> DQYJKoZIhvcNAQEFBQADggEBAHbIaTTqckaD1y/vCD4q8u09N66oVdbm4CCQLwdlYNO1u
>>> U
>>>>> guov8L
>>>>> 
>>> W+d8vJsANoGQ5aB349mzZVEJmfe9IrCWOS9R2MZi5u6PxsZFLiouD2LVldFZ/gA0tWqPp
>>> W+t
>>>>> W+y/HEwi
>>>>> 
>>> T9MJ+dujtjGuhUyQGJ/c/TAXYw+11URpdw/ulLO94pKhybMJlGuCD9Y6SugUUvRZfV9CG
>>> T9MJ+q
>>>>> T9MJ+3dA43k
>>>>> 
>>> EkvN7EUxhPSytjwr+X4mcJfzR1TV5D+nsb+Qh6tLYNVg750MJZkUdvs1SqWFQHaOGcfIe
>>> EkvN7EUxhPSytjwr+X4mcJfzR1TV5D+nsb+K
>>>>> EkvN7EUxhPSytjwr+X4mcJfzR1TV5D+nsb+rLgTKN
>>>>> 
>>> daSK/m87mPTCp04BO1A/pQcuekmI3ozmwP1XSCFzpsLnT1TbX3vfGluqgUu655kxggOJM
>>> I
>>>>> IDhQIB
>>>>> 
>>> ATBtMF8xEzARBgoJkiaJk/IsZAEZFgNvcmcxFTATBgoJkiaJk/IsZAEZFgVpY2FubjESM
>>> B
>>>>> AGCgmS
>>>>> 
>>> JomT8ixkARkWAmRzMR0wGwYDVQQDExRhZDEtbGF4LmRzLmljYW5uLm9yZwIKdWqXhgABA
>>> A
>>>>> AJHzAJ
>>>>> 
>>> BgUrDgMCGgUAoIIB8TAYBgkqhkiG9w0BCQMxCwYJKoZIhvcNAQcBMBwGCSqGSIb3DQEJB
>>> T
>>>>> EPFw0x
>>>>> 
>>> ODA1MjgwNTI2MTNaMCMGCSqGSIb3DQEJBDEWBBR8LUxI1LAn3WdertCUOSpR06a2zjB8B
>>> g
>>>>> krBgEE
>>>>> 
>>> AYI3EAQxbzBtMF8xEzARBgoJkiaJk/IsZAEZFgNvcmcxFTATBgoJkiaJk/IsZAEZFgVpY
>>> 2
>>>>> FubjES
>>>>> 
>>> MBAGCgmSJomT8ixkARkWAmRzMR0wGwYDVQQDExRhZDEtbGF4LmRzLmljYW5uLm9yZwIKd
>>> W
>>>>> qXhgAB
>>>>> 
>>> AAAJHzB+BgsqhkiG9w0BCRACCzFvoG0wXzETMBEGCgmSJomT8ixkARkWA29yZzEVMBMGC
>>> AAAJHzB+g
>>>>> AAAJHzB+mSJomT
>>>>> 
>>> 8ixkARkWBWljYW5uMRIwEAYKCZImiZPyLGQBGRYCZHMxHTAbBgNVBAMTFGFkMS1sYXguZ
>>> H
>>>>> MuaWNh
>>>>> 
>>> bm4ub3JnAgp1apeGAAEAAAkfMIGTBgkqhkiG9w0BCQ8xgYUwgYIwCgYIKoZIhvcNAwcwC
>>> w
>>>>> YJYIZI
>>>>> 
>>> AWUDBAEqMAsGCWCGSAFlAwQBFjALBglghkgBZQMEAQIwDgYIKoZIhvcNAwICAgCAMA0GC
>>> C
>>>>> qGSIb3
>>>>> 
>>> DQMCAgFAMAcGBSsOAwIaMAsGCWCGSAFlAwQCAzALBglghkgBZQMEAgIwCwYJYIZIAWUDB
>>> A
>>>>> IBMA0G
>>>>> 
>>> CSqGSIb3DQEBAQUABIIBAGnzDMiJdTOPXpJyTFeYUB2YBt8onPcISntBB1ohaYV82KwAF
>>> Y
>>>>> 7m8crG
>>>>> 
>>>> 
>>> qXogm9djUaaE31w4JyZEiX83pPrUW1OKPDIa6yY84QGIhZ2c+PKdD+EItxuF3vPKVrkagCg+q4V9
>>>>> 
>>> L8siqUtRctZnrMfMG4L7gp7pRMRZNiiSdXqCnKkxGIAnUBLyG0AnHG5plJ2xWxz/2IPhx
>>> E
>>>>> pfR84k
>>>>> 
>>> 6/oHS8XMBwADup4zfW/B8hh37p4hw64lLzohgRA5iRnYFKFjdVeDF5AXe67WvQPCITcV9
>>> H
>>>>> SXAWV9
>>>>> 
>>> W0lN52xhWzsOZkgV25sNzTvqog7NeKObagntuDlBRK/srrL4a4vhXPllySkAAAAAAAA=
>>>>> 
>>>>> ------=_NextPart_000_0060_01D3F66E.4DAD12E0--
>>>> 
>>>> 
>>>               _______________________________________________
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>>>     Idngwg at icann.org
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>>> 
>>> _______________________________________________
>>> Idngwg mailing list
>>> Idngwg at icann.org
>>> https://mm.icann.org/mailman/listinfo/idngwg
>> 
> --
> Kal Feher
> Melbourne, Australia
> 
> 
> 
> 
> _______________________________________________
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