[Rt4-whois] FINAL edit of the draft report - to be published [SEC=UNCLASSIFIED]

[Emily Taylor]

Hi Peter

Many thanks for spotting these anomalies.  With so many versions buzzing
around, it has been a real challenge to keep hold of everything.  I am
grateful you spotted this.

Alice- please can you amend.

Kind regards

Emily


On 8 May 2012 05:42, Nettlefold, Peter <Peter.Nettlefold at dbcde.gov.au>wrote:

> ** **
>
> Hello again all,****
>
> ** **
>
> Thanks Emily for circulating this for final comment.****
>
> ** **
>
> I have not had time yet to read it all, but did notice a couple of
> potential issues with the IDN text.****
>
> ** **
>
> The first is that the final paragraph of the revised findings that we
> worked on appears to have been dropped from the report (I’ve attached the
> email chain on this for reference). This read:****
>
> ** **
>
> These are difficult issues, and there is ongoing work within ICANN in this
> area (e.g. the joint gNSO and SSAC working group on Internationalised
> Registration Data – IRD WG). As the need is imminent, this work needs to
> proceed with priority in coordination with other relevant work beyond
> ICANN’s ambit, to make internationalised domain name registration data
> accessible.****
>
> Also, recommendation 12 remains in its original form in this version. I
> offered some comments on this on 3 May, and I’m concerned that this
> recommendation remains unclear. The current text reads:****
>
> ** **
>
> *12. *ICANN Community should task a working group within 6 months of
> publication to determine the relevant internationalized domain name
> registration data requirements and evaluate the available solutions,
> especially those being successfully implemented by ccTLDs, at least for the
> adoption of IDN gTLDs, as already stipulated by the New gTLD Applicant
> Guidebook.The working group should aim for consistency of approach across
> the gTLD and – on a voluntary basis – the ccTLD space, and report within a
> year of being tasked.****
>
> My comments from the 3rd were:****
>
> *12. *ICANN **[p1] <#1372ac1e1c8fe24b__msocom_1>** should task a working
> group within 6 months of publication to determine the
> relevant internationalized domain name registration data requirements and
> evaluate the available solutions. This should have particular regard to
> solutions **[p2] <#1372ac1e1c8fe24b__msocom_2>** being successfully
> implemented by ccTLDs, at least for the adoption of IDN gTLDs, as already
> stipulated by the New gTLD Applicant Guidebook**[p3]<#1372ac1e1c8fe24b__msocom_3>
> ** . The working group should aim for consistency of approach across the
> gTLD and – on a voluntary basis – the ccTLD space, and report within a year
> of being tasked.****
>
> I’m still unclear on whether the intent is to recommend that the
> ‘solution’ be imposed on all IDN gTLDs and/or recommend consistency across
> the whole gTLD space?****
>
> ** **
>
> I offer the below, based on my best guess of the current intent. I’m not
> trying to alter the intent, only to clarify what is being recommended, so
> look forward to any comments on this:****
>
> ** **
>
> *12. *ICANN should task a working group within six months of publication
> of this report, to determine appropriate internationalized domain name
> registration data requirements and evaluate available solutions (including
> solutions being implemented by ccTLDs). At a minimum, the data requirements
> should apply to all new gTLDs, and the working group should consider ways
> to encourage consistency of approach across the gTLD and (on a voluntary
> basis) ccTLD space. The working group should report within a year of being
> tasked.****
>
> I hope this helps.****
>
> ** **
>
> Cheers,****
>
> ** **
>
> Peter****
>
> ** **
>
> ** **
>
> ** **
>
> *From:* rt4-whois-bounces at icann.org [mailto:rt4-whois-bounces at icann.org] *On
> Behalf Of *Emily Taylor
> *Sent:* Tuesday, 8 May 2012 12:10 AM
> *To:* Alice Jansen; rt4-whois at icann.org
> *Subject:* [Rt4-whois] FINAL edit of the draft report - to be published***
> *
>
> ** **
>
> Dear Alice, dear All****
>
> ** **
>
> On our last call, you empowered me and Kathy to have a final, final edit,
> once the whole report was put together.  I have spent much of today working
> through the whole report, and attach a mark up showing some minor changes
> that I recommend making.  ****
>
> ** **
>
> As predicted, the new text combined with the old has created a few
> anomalies.  In addition, there are one or two places where I have made
> changes (eg where public comment suggested we should make clear that we're
> not advocating going behind PDPs or existing processes - we all agreed to
> this, but forgot to put it in).  I have listed them all out below for
> maximum transparency and so that you can see what I've done at a glance.
>  They are also marked up in the  attached version.  My approach through out
> has been minimalist, and to move existing text rather than amend it.
>  Sometimes, I've had to create new words, but have stuck to areas where I
> know we all agree, rather than plunging into controversial areas.****
>
> ** **
>
> Alice has also done things like make sure "WHOIS" is consistently
> capitalised throughout.  She will also go through one more time and clear
> up anomalies in US and UK spelling.  ****
>
> ** **
>
> *The way forward: I am asking Alice to accept all these changes now,
> produce a content page, and have the report published.*****
>
> ** **
>
> *IF YOU HAVE ANY FINAL COMMENTS (PARTICULARLY ON LATEST CHANGES) PLEASE
> LET ALICE AND ME KNOW AS SOON AS POSSIBLE.*****
>
> ** **
>
> ** **
>
> Kind regards****
>
> ** **
>
>
> Emily****
>
> ** **
>
> *---------------*****
>
> ** **
>
> ** **
>
> ** **
>
> ** **
>
> So, here is a run down of the changes that I have made:****
>
> ** **
>
> *Executive Summary, Findings and Recommendations*****
>
> ** **
>
> Page 5 - the new language on studies was there along with the original
> wording.  We agreed to keep the original wording, and sort of liked the new
> language.  Reading the Exec summary through again, I find they duplicated
> and so went back to the original wording.  ****
>
> ** **
>
> Page 5 - removed the title "Conclusions" which led into original text.
>  This had been removed, then reinstated, and again reading it through the
> whole Exec Summary came across as a lot of conclusions, followed by
> findings etc.  So, removing the title, includes much of the text as
> continuing the "Debate" point, where it originally was.  I also moved the
> paragraph about "Consumer Trust" to the Findings section before
> Recommendations 3 where it works very well, and introduces the Consumer
> study into our findings (it wasn't there before, which I think was an
> omission).****
>
> ** **
>
> Page 5 - moved the original wording describing the Review Team's diversity
> etc to the final paragraph of "Work of this Review Team" on the following
> page.****
>
> ** **
>
> Page 7 - Removed the word "honest" (a hangover from my original, bad
> tempered draft, subsequently toned down and this was missed), and changed
> "and encourage the " to "encouraging" to fit with the language of the rest
> of the sentence in the findings to Strategic Priority (rec 1).  I also put
> in a footnote describing the NORC study where first mentioned.  It fits
> better to go into a full definition in the text on Data Accuracy findings
> (as is).****
>
> ** **
>
> Page 7 - it's marked as me, but I picked up and included text edits
> proposed by Peter on the Exec Summary (eg "the" included in 5th bullet
> point on page 7)****
>
> ** **
>
> Page 8 - Peter's text included in second paragraph of Findings to Rec 3,
> and paragraph moved from original exec summary on consumer study, with
> first sentence tweaked to keep the flow.****
>
> ** **
>
> Page 10 - Susan's wording and footnote explaining definitions included in
> the findings on Data Accuracy (NORC study terms).****
>
> ** **
>
> Page 11 - A section starting "Anecdotal evidence suggests..." is added
> into the para on WDRP to fit with the Findings and Recommendations at the
> end of the report (which included this text inserted from the original
> "Findings")****
>
> ** **
>
> Page 12 - Added "in accordance with ICANN's existing processes" in the bit
> about WDRP to reflect feedback from public comment, which suggested that it
> reads like we're trying to bypass PDP.****
>
> ** **
>
> Page 15 - the text for findings is new.  It was agreed on the list a
> couple of days ago.****
>
> ** **
>
> Page 16-17 - the order of the final two recommendations has been reversed
> as agreed, and consequential changes made.****
>
> ** **
>
> *Main report*****
>
> ** **
>
> Page 18 - in response to feedback that said it looked as if I was claiming
> to be Chair of the ccNSO, I have created a table for the membership of the
> Review Team, rather than the previous bullet point format.****
>
> ** **
>
> Page 36 - new Chapter 4 - I have changed the reference to Findings and
> Recommendations (which were originally included in the chapter itself).***
> *
>
> ** **
>
> Page 37 - we need to add in the references to Appendix numbers when they
> are published, and also double-check that page numbers for the report
> itself are accurate.****
>
> ** **
>
> Page 37 - date of letter to compliance team is added.****
>
> ** **
>
> Page 41 - two "also"s removed.  Appendix numbers need adding.****
>
> ** **
>
> Page 42 - emphasis added to quotation about budget, and "emphasis added"
> is included in text.****
>
> ** **
>
> Page 42 - dates changed, and additional text brings this passage up to
> date.  Footnote added "considered narrowly" in the text.****
>
> ** **
>
> *Gap Analysis*****
>
> ** **
>
> We had not really revisited this in the light of our updated findings and
> recommendations.  Mostly, it's still very good, but there were a couple of
> anomalies.****
>
> ** **
>
> Page 75 - removed "Conclusions" as these are now incorporated into
> Findings with the recommendations.  Full and Substantial Failure are
> included in keeping with our findings and recommendations on data accuracy
> ****
>
> ** **
>
> Page 76 - included short paragraph on compliance budget/staffing which
> lays the foundations for the findings.****
>
> ** **
>
> Page 78 - this passage on The Proxy Registration System reflected the
> state of play on publication of our draft report - ie that we were making
> separate recommendations for privacy and proxy providers, and two
> alternatives for "common interface".  The situation has now changed.  I
> have dealt with this by removing a few paragraphs that talk about us not
> reaching consensus, and being sceptical about whether our recommended
> "voluntary best practices for proxies" would work.  Removed the reference
> to alternatives completely on "Common Interface". and added a few words to
> try and pull back the sense on how all this relies on a functioning
> compliance team to work out.****
>
> ** **
>
> Finally, I went through the Findings and Recommendations as set out in the
> Exec Summary and at the end of the report. They should be identical, and as
> noted above I made a few changes for consistency (where one had changed but
> not the other).****
>
> ** **
>
> ** **
>
> ** **
>
> ** **
>
>
> ****
>
> ** **
>
> --
>
>
>    ****
>
> *
> *
>
> 76 Temple Road, Oxford OX4 2EZ UK
> t: +44 (0)1865 582 811 • m: +44 (0)7540 049 322
> emily at emilytaylor.eu
>
> *www.etlaw.co.uk*
>
> Emily Taylor Consultancy Limited is a company registered in England and
> Wales No. 7630471. VAT No. 114487713.****
>
> ** **
> **
> ------------------------------
> **
> **
> ******
>
>  **[p1] <#1372ac1e1c8fe24b__msoanchor_1>**PN – I assume we’re asking
> ‘ICANN’ to this?
> **
> **
> **
> ******
>
>  **[p2] <#1372ac1e1c8fe24b__msoanchor_2>**PN – I have not tried to change
> the intent, only to break the sentence in two – as the sentence was very
> long, and risked being unclear.
> **
> **
> **
> ******
>
>  **[p3] <#1372ac1e1c8fe24b__msoanchor_3>**PN – I’m not 100% clear on what
> is intended here by the phrase ‘at least for the adoption of IDN gTLDs’.
> Does this mean the solution should be adopted *by* all IDN gTLDs? If so,
> I don’t think it’s currently 100% clear. Also, how does this fit with the
> following sentence which talks about aiming for ‘consistency across the
> gTLD…space’? I may be missing something, but while I support the intent of
> this recommendation – it’s not 100% clear to me.
> **
> **
>
>
> *
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>
>
> ---------- Forwarded message ----------
> From: "Sarmad Hussain" <sarmad.hussain at kics.edu.pk>
> To: "'Kathy Kleiman'" <kathy at kathykleiman.com>, "'Emily Taylor'" <
> emily at emilytaylor.eu>
> Cc: "rt4-whois at icann.org" <rt4-whois at icann.org>
> Date: Sat, 5 May 2012 02:34:33 +1000
> Subject: Re: [Rt4-whois] Fwd: IDN - a few more changes to bring it up to
> the readability of the rest of the Summary [SEC=UNCLASSIFIED]
>
> I am Ok with the revisions.  ****
>
> ** **
>
> Regards,
> Sarmad****
>
> ** **
>
> ** **
>
> *From:* rt4-whois-bounces at icann.org [mailto:rt4-whois-bounces at icann.org] *On
> Behalf Of *Kathy Kleiman
> *Sent:* Friday, May 04, 2012 9:20 PM
> *To:* Emily Taylor
> *Cc:* rt4-whois at icann.org
> *Subject:* Re: [Rt4-whois] Fwd: IDN - a few more changes to bring it up
> to the readability of the rest of the Summary [SEC=UNCLASSIFIED]****
>
> ** **
>
> I like it, tx Peter and Emily. However, I defer to our lead IDN drafters,
> Sarmad and Michael, for final approval.
>
> What I like is that it helps makes the whole issue approachable -- and
> hopefully the rest of the Community will spend more time and attention on
> this issue in which a core of dedicated people have worked so hard and so
> well.
>
> Best,
> Kathy
>
>
>
>
> ****
>
> Thank you Peter ****
>
> ** **
>
> I think this is a good synthesis.   One extra element, which is easily
> forgotten, is that internationalised WHOIS data isn't just an IDN problem,
> but one which has been around ever since Chinese, Arabic and Russian
> speakers have been registering domain names.  So, the delay in addressing
> this has not just been a year (since introduction of IDN.IDN) or a decade
> (IDN.tld), it's even longer than that.****
>
> ** **
>
> So, I've added some language for this, based on the first paragraph of the
> IDN chapter (highlighted below).****
>
> ** **
>
> Kind regards****
>
>
> Emily****
>
> On 4 May 2012 08:08, Nettlefold, Peter <Peter.Nettlefold at dbcde.gov.au>
> wrote:****
>
> Hello again all,****
>
>  ****
>
> As I’ve said previously, I’m no expert in this area, but to hopefully help
> move this forward I have attempted to pick up what seemed to be the major
> themes from both sets of text.****
>
>  ****
>
> I hope this helps, and please feel free to edit or discard as needed.****
>
>  ****
>
> Cheers,****
>
>  ****
>
> Peter****
>
>  ****
>
>  ****
>
> *Findings*****
>
>  ****
>
>  Developments associated with the WHOIS protocol and registration data
> have not kept pace with the real world. A significant example of this is
> International Domain Names (IDNs). IDNs have been available for
> registration at the second level for over a decade, and were introduced in
> 2010 at the root level. However, these developments were not accompanied by
> corresponding changes related to WHOIS. In short, the current WHOIS
> protocol has no support for non-ASCII characters, and cannot signal a
> non-ASCII script.****
>
>   This means that while domain names can now be written in a range of
> scrips (such as Arabic and Cyrillic), the contact information must still be
> transliterated into a format ill-suited to the purpose. The NORC Study on
> Data Accuracy highlighted IDN contact data as a major cause of apparent
> inaccuracy.  ****
>
>  ** **
>
> The failure to reflect internationalised registration data does not just
> affect IDNs, however, and has existed for much longer - ever since domain
> names have been registered by registrants globally.  Global users need to
> represent their local names, postal addresses and other contact and
> technical information in the script(s) which they use.   ****
>
>   ****
>
> These are difficult issues, and there is ongoing work within ICANN in this
> area (e.g. the joint gNSO and SSAC working group on Internationalised
> Registration Data – IRD WG). As the need is imminent, this work needs to
> proceed with priority in coordination with other relevant work beyond
> ICANN’s ambit, to make internationalised domain name registration data
> accessible.
>  ****
>
>  ****
>
> *From:* rt4-whois-bounces at icann.org [mailto:rt4-whois-bounces at icann.org] *On
> Behalf Of *Kathy Kleiman
> *Sent:* Thursday, 3 May 2012 11:43 PM
> *To:* rt4-whois at icann.org
> *Subject:* [Rt4-whois] Fwd: IDN - a few more changes to bring it up to
> the readability of the rest of the Summary****
>
>  ****
>
> Dear All,
> I appreciate the evolution of the IDNs text (and see nice changes in the
> findings). Canwe go a bit further? I was wondering if we might take one
> more attempt to a) define IDNs (for the many readers who will have no
> idea), b) and define better the ambiguous term "this environment".
>
> For smarter (and more awake) people than I am, do you see a way to merge
> the two texts below? I truly want to make sure that everyone understands
> the importance and timeliness of our recommendations!
>
> Also, I saw that Peter has some ideas in this area, but did not propose
> wording changes (I don't think). Does some of the text below cover your
> thoughts?
>
> Best and tx,
> Kathy
>
>
> *Findings/Kathy:
> *[from the Executive Summary] Policy and implementation of the Whois
> protocol and registration data have not kept pace with the real world.
> International Domain Names (IDNs) were introduced to great fanfare by ICANN
> in 2000, and in 2010 at the root level, without a corresponding change to
> its policies related to WHOIS.
>
> What this means, is that while domain names can now be written in Arabic
> for example, the contact information for these domains must still be
> transliterated into a format ill-suited to the purpose. [from the Public
> Forum Slides] These are difficult issues, and members of the ICANN
> Community have worked hard to date, but the current Whois protocol has no
> support for non-ASCII characters and cannot signal a non-ASCII script. Some
> ccTLD registries and registrars have implemented ad hoc solutions and
> arbitrary mappings of local scripts onto ASCII code points, and as a
> result, IDN Whois data today often appears as a nonsense sequence of ASCII
> characters.
>
> *Findings/Sarmad
> *Perhaps it should be no surprise that within this environment [*Kathy:
> which environment?] *, policy and implementation have not kept pace with
> the real world.  A significant example of this is Internationalised Domain
> Names (IDN), which have been available for registration at the second level
> for over a decade, and at the Top Level for more than a year. During this
> time, WHOIS policies were not amended to accommodate the obvious need to
> support non-ASCII character sets even though there was a recognition that
> Internationalisation is essential for the Internet’s development as a
> global resource. There is ongoing work within ICANN (e.g. joint gNSO and
> SSAC working group on Internationalised Registration Data – IRD WG) in this
> area.  As the need is imminent, this work needs to proceed with priority in
> coordination with other relevant work outside the ICANN’s ambit (e.g.
> WIERDS initiative at IETF), to make internationalised domain name
> registration data accessible.
>
> The NORC Study on Data Accuracy highlighted IDN contact data as a major
> cause of apparent inaccuracy.  Having internationalized data will also
> address this source of inaccuracy.
>
> [end]****
>
>
> *
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>
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> ** **
>
> --
>
>
>    ****
>
> *
> *
>
> 76 Temple Road, Oxford OX4 2EZ UK
> t: +44 (0)1865 582 811 • m: +44 (0)7540 049 322
> emily at emilytaylor.eu
>
> *www.etlaw.co.uk*
>
> Emily Taylor Consultancy Limited is a company registered in England and
> Wales No. 7630471. VAT No. 114487713.****
>
> ** **
>
> ** **
>
>


-- 




*
*

76 Temple Road, Oxford OX4 2EZ UK
t: +44 (0)1865 582 811 • m: +44 (0)7540 049 322
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*www.etlaw.co.uk*

Emily Taylor Consultancy Limited is a company registered in England and
Wales No. 7630471. VAT No. 114487713.
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