[Comments-o-com-single-char-10may18] Comment on Release for Registration one .COM Domain Name with a Single-Character Label: O.COM

[JS Lascary]

It occurred to me that the Registry Service request from the registry
operator, VeriSign, Inc. (hereinafter the 'Request') is in conflict with
ICANN's Final Proposed Draft v. 4.0 of the IDN Guidelines  (hereinafter the
'Guidelines') as published at the following uri <
https://www.icann.org/en/system/files/files/idn-guidelines-10may18-en.pdf>.

Specifically, section 2.5.3 of the Guidelines mentions that :

" TLD registries are encouraged to apply additional constraints on
registrations that minimize Whole-Script Confusables as determined by
Unicode Technical Report #36: Unicode Security Considerations (
http://unicode.org/reports/tr36) and Unicode Technical Standard #39:
Unicode Security Mechanisms (http://unicode.org/reports/tr39). "

In fact, the single character domain name proposed in the Request, o.com
(Latin script), is Whole-Script Confusable with xn--0xa.com (Greek Script)
and xn--n1a.com (Cyrillic Script). At the time of this comment, the latter
two are registered in the .com namespace and have been for over 14 years.

Given the above, I would welcome clarifications on the below points for the
benefit of the entire ICANN community :
(i) What is each stakeholder's position on the matter. I note neither the
Request nor ICANN's Review of the Request discuss the issue of Whole-Script
Confusables. Moreover, there is no published policy on Whole-Script
Confusables for the .com namespace at this time.
(ii) Assuming both the Guidelines and the Amendment to the .com Registry
Agreement are adopted contemporaneously, will Verisign be required to
update its .com IDN policy to reflect the Guidelines prior to proceeding
with it's plan to release any single character domain name.
(iii) What are the "additional constraints on registrations that minimize
Whole-Script Confusables" envisioned by Verisign.
(iv) In which scenario(s) can the domain name  proposed in the Request,
o.com (Latin script), be safely released in accordance with the Guidelines.

Many thanks,
Jean-Sebastien Lascary

cc idngwg at icann.org
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