[Comments-managing-idn-variant-tlds-25jul18] Comments to Recommendations for Managing IDN Variant Top-Level Domains

[liangshuo at knet.cn]

we make the following comments to "Recommendations for Managing IDN Variant Top-Level Domains" published by ICANN at  https://www.icann.org/public-comments/managing-idn-variant-tlds-2018-07-25-en:

1. In order to “avoid including variant TLDs in a manner that would create user vulnerabilities or a probability of confusion”, and to ensure the healthy and stable operation of the domain name system, we agree with ICANN recommendations: IDN variant TLDs {t1, t1v1, …} allocated to the same entity, same second level labels under IDN variant TLDs s1.{t1, t1v1, …} registered to the same entity, and Second-level variant labels under IDN variant TLDs {s1, s1v1, …}.{t1, t1v1, …} registered to the same entity.

2. According to the premise that “Active IDN variant TLDs should be minimized”, we agree to strictly manage the IDN variant TLDs, and the IDN variant TLDs should be applied by each IDN registry based on actual conditions. 

3. We recommend that the registry of IDN variant TLDs should develop its own registration and price policy for the second-level domain under IDN variant TLDs, under the principle that "Same second level labels under IDN variant TLDs s1.{t1, t1v1, …} registered to the same entity".
In addition, the management of the IDN variant TLDs and its second level labels follows the management of the primary domain name. It is recommended to pay only the primary domain name management fees to ICANN. For example, the primary IDN TLD is t1, and the variant TLD is t1v1, then only pay ICANN the management fee for t1.  In the case of Chinese IDN variant TLDs. Chinese includes Simplified Chinese and Traditional Chinese. Without considering the simplified and traditional form of second-level domain, registrants need to register "s.t1" and "s.t1v1" two domain names, and may pay 2 registration fees. In this case, it is likely that the registrant will only select one of the domain names to register. After all, another domain name will be reserved for the same registrant. This registration policy is not conducive to the common development of Simplified Chinese domain names and Traditional Chinese domain names.

4. We agree that "IDN variant TLDs {t1, t1v1, …} allocated to the same entity", but we disagree that "each variant label in a set should be a separate TLD application". For example, Simplified Chinese is simplified from Traditional Chinese. These two Chinese characters are corresponding; And Simplified Chinese and Traditional Chinese are distributed in different regions, they are coexisting and intersecting. The simplified and traditional form of a Chinese domain name is like the capitalization and lower case of an English domain name. It should not be a separate TLD application.

5. We recommend that the IDN Variant TLD application can apply Fast Track Requests. As long as IDN TLDs and their variant labels defined by the RZ-LGR, it is eligible for application. If the existing IDN TLD operates compliance with ICANN's operating standards for registries, and promises to comply with the basic principle of "Recommendations for managing IDN variant TLDs", the application complying with RZ-LGR shall get the approval and delegation.


Best Regards,

Lisa Liang
KNET Co., Ltd.

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