Discussion Paper on Non-ASCII
TLD Policy Issues
Summary of Public Feedback
I. NON ASCII TLD CREATION PRINCIPLES
Response from Kilnam Chon
"sudden introduction of a massive number of new TLDs would be a bad idea"
I don't agree with this statement. We introduced the massive number
of ccTLDs in mid 1980s, but did not have any serious problems. The
important issue is "how to introduce TLDs".
Response from Danny Younger
“a new TLD should only be introduced if user
demand can be demonstrated to exist.”
I question whether in fact we have the metrics to gauge the degree of
user demand for products that are not yet on the market, and further whether
it is up to ICANN to become the barometer of the market. Clearly
there was no pressing "user" demand for .museum (as compared to what-seemed-to-be
a market demand for .web), and yet that TLD was introduced without such
a constraining principle on a proof-of-concept basis.
Why not allow for the marketing of any such IDN string by any responsible
registry operation that is willing to take the risk, and thereby allow
the market to determine if there is sufficient user demand to sustain
the operation. Some registries may indeed fail as user demand might
not materialize... but this is what proof-of-concept is all about.
Response from Mr. S. Maniam, Chairman WG03 of the International Forum
for IT in Tamil (INFITT) and Chairman MINC Tamil Language Working Group,
Approved by Executive Director, INFITT.
“TLD expansion should occur in a careful and controlled fashion,
with regard for the overall stability of the DNS”
Limiting TLD expansion with the unfounded fear of affecting
the overall stability of the DNS has over the years, been often invoked
as a stockphrase that has not been backed by experimental data. Using
this as a basic premise to slow down the implementation and deployment
of a new technology and a new namespace would be unacceptable to the Tamil
”(T)he sudden introduction of a massive number of new TLDs would
be a bad idea”
Re-using this oft-quoted premise is generally a bad idea as the history
of ICANN has shown, and merely reinforces the misconception that ICANN
is a bureaucracy unable to respond quickly enough to the pace of Internet
growth and innovation. It is our opinion that ICANN be seen as a proactive
organization, rather than have an international organization tarred by
this kind of obscurantist and unnecessary phraseology.
”(A) new TLD can only be created if there is a willing and able
registry operator to run it”
This principle is generally sound but safeguards should be instituted
to prevent this principle from being abused as an excuse to shut out new
namespaces particular in those places where a language namespace may be
associated with developing countries, where the standards and yardsticks
used to assess willingness and ability to perform registry operations
are those of developed countries, and thus become disproportionate and
not commensurate with the stage of evolution of Internet in these countries
”(D)ifferent categories of new TLDs may require different contractual,
policy, and selection frameworks”
While this principle may be true generally speaking, it belies the underlying
assumption and premise that is fundamentally flawed because that was not
how the Internet became such an unprecedented success in the history of
By having an open framework, the unfettered growth of the Internet has
been unprecedented. Anyone who wanted to set up a network could do so
by connection to a service provider, without having authorities to evaluate
contractual, policy or worse, selection criteria and frameworks.
Basing the future process of the non-ASCII domain name space on such a
counter-Internet culture is detrimental to the growth of the Internet
in non-ASCII using communities and places unnecessary strictures on Internet
accessibility in the name of care, control and stability. Instead, one
strong recommendation would be the lightest touch of policy and regulation,
so as to facilitate growth.
”(T)he selection process should be transparent, allowing key stakeholders
to participate in it.”
As the ICANN's recent history has demonstrated, the inability to properly
define stakeholders generally leads to ineffectual execution of well intentioned
policies. Transparency is sound and desirable. Essentially, participation
in language or script-specific name spaces should be left to the community
of language/script users to decide for themselves. Non-language speakers/users
should not interfere with other language/user groups and allow them self-determination.
The market forces and the evolutionary pressures will do the rest.
”(T)he core purpose of introducing non-ASCII TLDs would be to make
the DNS service easier to use for Internet users whose native languages
include non-ASCII characters”
This principle is sound, fair and magnanimous and should be actively pursued
for a level playing field for language and script using communities world
wide, so as to build an Internet for all peoples everywhere.
”(A) new TLD should only be introduced if user demand can be demonstrated
This is an unnecessary bureaucratic requirement which is superfluous.
Creation and destruction of domain names on the Internet are currently
dynamic and fluid. Depending on usage, the survival of the domain names
obeys the laws of nature and the market forces of demand and supply, that
is not easily pre-determined or pre-demonstrated.
The creation of so-called non-ASCII TLDs should also not be artificially
constricted by arbitrary concepts of user demand which do not have
technical or engineering bases.
If the Tamil speaking community would like to have Tamil TLDs, and the
technology allows for it, this should be facilitated whether or not there
is user demand.
The inability to define "user demand" opens it to abuse. Is one user sufficient
user demand, or ten thousand or ten million? Or is it relative user demand
that this principle is based on? If so, relative to what? the population
of China? or the population of Mauritius? Once this principle is invoked,
there is no objective yardstick and if adopted, merely opens up more complexity,
confusion and chaos.
II. REGISTRY REQUIREMENTS
Response from Stefan Probst
They differ now already between a TLD and say a 3rd-level-domain. I see
no reason, why the requirements for e.g. the ".com" registry have to be
the same [stringent] like the ones for a small language community in a
developing country, which is accustomed to non-reliable infrastructure.
Also operating cost differ. I do not believe that ICANN/IANA is able to
judge the financial ability of a registry in a developing country.
III. SEMANTIC MEANING
Response from Stefan Probst
In addition to that resource requirements, there is also the issue of
global equivalences. Just two examples:
- While there might be a fairly clear definition for the .coop in the
West, who knows, what kind of cooperatives exist in other political systems?
Who defines what qualifies, and what not?
- The .name is based on a Western naming system with family name and surname,
where both names can be arranged in either way. There are surely many
cultures, where this does not fit. Why should they not be allowed to have
their own TLD for their individual-name-based domains?
Again, there should be no automatic linkage between non-ASCII TLDs with
the ASCII versions in your category of sponsored and unsponsored gTLDs.
IV. INCUMBENT PREFERENCE
Response from James Seng
I do not believe in any incumbent preference for gTLD or ccTLD or for
the government. However, I recognized that they are likely candidate to
submit an application and also likely to have the community support for
Response from Stefan Probst
I oppose therefore any regulation, procedure, etc. which would give "rich"
corporations and organizations in the West any advantage over "poor" ones
in the developing world.
This applies especially, but not exclusively, to any linkage between non-ASCII
TLDs with the ASCII versions in your category of sponsored and unsponsored
V. IDN TAXONOMY
Response from James Seng
Divided by either geographic, language or culture is possibly a bad idea.
There is no single well define rule to draw that line. For example, have
a TLD for every geographic is easy but it only capture the country level
TLD.It does not capture the other generic use or for languages which have
no country (e.g. Tamil, Mongolian). having a TLD for every language or
culture is also problematic as it does not capture the ccTLD, or at least
in the "normal" way. And by creating and delegating a TLD to every language/culture,
the problem also exist which group to delegate to and also the legitimacy
of the organization, and their process. Delegating only creates multiple
mini-ICANN, and worst, one which may not adopts the similar open process.
I suggest looking into a generic creation process. For instance, an application
for any TLD would be up for open comments for a period of time (3/6/12
months) and from the feedbacks, an appointed group would make a rough
consensus call. The key word is _rough_ (in IETF terms that is around70-80%),
because it is unlikely any proposal would receive 100% consensus.
A well-defined (e.g. narrowly defined) TLD is therefore likely/easier
to get through this process vs. a more generic TLD. It is both an advantage
and disadvantage of such a system.
VI. IDN SELECTION RULES
Response from James Seng
The lack of ISO-3166 for non-ASCII TLD is both a problem for ccTLD and
gTLD. And there is not just one firm "translation", even within a single
language. Therefore, it is better to consider a generic creation policy
for all non-ASCII TLD (regardless of ccTLD or gTLD) rather relying on
Depending on the TLD requested, the vested interest parties may be within
a specific region of a specific language, specific to a country or across
multiples locale. This is much like the ccTLD and gTLD interest, one which
covers a specific country the other worldwide. In IDN case, there is an
additional twist of language/script consideration.
I foresee that the applicant of the non-ASCII TLD would have to submit
these (sic) information and demonstrate support from the relevant locale.
All players, ccTLD, government, non-profit, commercial and at-large have
a vested interest in the TLDs. Therefore, there should not be any special
incentive (or roles given) to any of the vested parties. All comments
should be treated equal, regardless whether it comes from a ccTLD, a government,
non-profit, commercial or at-large.
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