To round it up, here are at least 3 groups with interest to see T/T done: law enforcement, security and intellectual property. There are resources within these groups to subsidize. Over to the ALAC. There is sufficient information to make a decision on whether to respond to the WG request for input from SO/AC. Best regards, Rinalia On Feb 19, 2014 3:21 AM, "Alan Greenberg" <alan.greenberg@mcgill.ca> wrote:

Carlton's EWG is looking at whether T/T is needed in a new registration database. I can easily see them deciding that T/T is not needed. If the registration data is in Chinese and Arabic, simply put that into the equivalent of Whois, and if someone needs to read it, it is their problem to decypher it. My understanding is that the current T/T is focused on today's world of an ASCII Whois which cannot represent Whois information that is purely in a language/script that cannot be formatted in 7-bit ASCII. At issue is the usability of Whois information for these domains.

Alan

At 18/02/2014 01:51 PM, Evan Leibovitch wrote:

I hadn't planned to get involved in this discussion, but I see some hot buttons being pushed.

- The question of "should it be done" rather than "who pays" is being dealt with at the EWG, as Carlton says, and I am hesitant to comment on that matter until their work is done. - Regarding "who pays": unless registries are to be subsidized by ICANN for T/T functions, I'm not sure it is at all viable, let alone reasonable, to demand that costs not be borne by those who ultimately are using the services. Demanding that registrars and registries not have the flexibility to adjust prices based on their expenses is dangerous territory. A requirement that such costs not be levied as a separate fee -- but rather be buried in the core prices -- is a form of financial micromanagement that is not necessarily worth the effort. - In domains, T/T is not IMO necessarily a right. I don't expect to be able to demand English processes from a site regarding a TLD catering to a non-English audience. If it is provided, that is an extra service -- an optional one, for which I might expect to pay more (or use an external translation service). In a competitive environment comprising hundreds of TLDs, some will cater to my particular needs -- linguistic and otherwise -- more than others. That is the design of the program. - As for "end users" versus "registrants" as the core of At-Large's concern, that is a thorny issue but one that comes up frequently. I am interested to see if the registrant side of the GNSO -- the BC, NCUC and NPOC, to be specific -- share this concern about who bears the costs of T/T. I would be hesitant to make any pronouncement in support of registrants that does not have at least noticeable support within ICANN's existing registrant stakeholder groups. - In the absence of such support from elsewhere in ICANN, I am hard pressed, from the Internet end-user-centric viewpoint, to make a case either way regarding who pays for T/T functions and how it is paid.

So I would suggest that we can wait for a statement until the EWG and approproate At-Large working groups are further along. As Rinalia says, there will be future opportunities to comment once the new information is in our hands.

And ... it is IMO redundant to make a statement simply saying we reserve the right to comment later.

- Evan

On 18 February 2014 12:39, Rinalia Abdul Rahim <rinalia.abdulrahim@gmail.com> wrote: Hi, Alan.

Your detailed knowledge is always enriching and very useful.

I don't believe we are in disagreement. It is more a matter of approach.

I don't think I have seen the push-back in the At-Large in supporting registrants. This may have predated my engagement. In principle, I see some value in supporting registrants in that they provide content and services for end users. And certainly we should not be supporting them in cases where it harms end users.

In moving forward on this, I think the ALAC needs to make a decision. As you mentioned there is a myriad of activities on the topic from various groups. I don't believe we are ready with detailed responses on each of the questions - it is also possible that end user comments on most of the questions are non-existent. What might be helpful to "influence" the thinking on policy options within those groups is to convey what the ALAC considers as the principle early on. If the principle is conveyed, then the ALAC can see what policy options are generated and say "yes, we support this" or "no, we reject this" based on the principle.

Best regards,

Rinalia

On Mon, Feb 17, 2014 at 1:01 PM, Alan Greenberg <alan.greenberg@mcgill.ca>wrote:

...

I know of no cases where an explicit translation/transliteration fee is charged. The entire domain registration process is ultimately largely funded by registration fees, to the extent that we are privy to registrar and registry internal finances (perhaps some registrars subsidize registrations with income from other lines of businesses, but that is beyond our knowledge or control). So if there is a T/T cost, it is ultimately either explicitly charged to registrant (not likely in my mind) or buried in the overall costs of the registration.

I wasn't trying to make any stronger point that to say that since most costs associated with registrations are incorporated in registration fees, we need more specificity than simply saying the registrant shall not pay.

In today's ASCII world, if a registrar is required to create an ASCII Whois record (as they are!), and the registration is done in some other script, then somewhere a conversion needs to be done. Today, to the extent that they honour the RAA requirement, the registrar needs to create ASCII text that goes into the Whois record. So they bear the cost. If I understand your point, you are saying that this cost must be born by the registrar as a cost of doing business and should not explicitly be levied on the registrant. I don't think we can say anything stronger. There is no way we can control (or even recognize) that a domain is more expensive in Beijing than in Dallas and attribute it to the T/T cost (as opposed to cost of rent or taxes or bribes!).

Regarding whether we should advocate for registrants, instead of just "users". There was a lot of push-back in At-Large when I advocated such actions. The balance that we struck (and it is not violated in this case) is that to the extent that advocating for registrants does not measurably harm non-registrant users, then we are definitely in the business of supporting registrants.

Alan

At 16/02/2014 10:32 PM, Rinalia Abdul Rahim wrote:

Alan,

What a multiplicity of effort. One wonders if anyone ever gets confused in ICANN.

On your comment regarding registrants pay ALL of the cost for translation and or transliteration - Can you clarify if that is an assumption based on examples in other areas implicating registrants or are there registrants that are currently required to translate or transliterate when they register?

Here is my view: The core/fundamental consideration in translation and / or transliteration is whether it is meant for general use or specialized use. If the former, the principle should be that the cost is borne by the process that collects the information (i.e, registry/registrar). If the latter, the entities requiring translated/transliterated data pay for the specialized service. The key issue is whether or not the principles can be enforced so that the cost is not transferred to registrants.

The ALAC should make a stand on the issue on behalf of the registrants, who comprise part of the consumer group that it advocates for. It should begin by saying that under no circumstances should the Registrants have to pay for it and steps must be taken to ensure that costs are not transferred to registrants (which among others would include the requirement of information transparency to track price differentials etc as you mentioned in your mail).

Best regards,

Rinalia

On Mon, Feb 17, 2014 at 10:59 AM, Alan Greenberg < alan.greenberg@mcgill.ca > wrote: Ultimately, registrants pay ALL of the costs, since they are the only significant source of funding. The only substantive issue (that I see) is how much obfuscation there is in tracing and attributing any translation/transliteration cost and whether the registry/registrar can be seen to be charging differential fees based on whether T/T is needed. The only other potential funder is those who look at the data, and that is a MUCH smaller pool by several orders of magnitude and not likely a useful source for funding what may be a significant cost.

Note that presumably the Registration EWG is working with an assumption that the great new registration system in the sky will not be limited to 7-bit ASCII, so the question that they are looking at is different from the one today where we are, for the known future, subject to that limitation. I note that there is ANOTHER expert working group looking specifically at the T/T issue in parallel with the PDP.

NOTE TO STAFF: In converting the e-mail at the start of the workspace to PDF format, all of the hyperlinks to the background documents were lost.

Alan

At 16/02/2014 08:05 PM, Rinalia Abdul Rahim wrote: Thanks for the information, Carlton. Olivier, the ALAC needs to decide if it wishes to submit a view to the WG at this stage or wait to see the EWG view on the matter.

An option to consider: For now, send a simple, but clear message to the WG that says the ALAC firmly believes that Registrants should not have to bear any of the cost burden for translation and / or transliteration of registration contact data.

The rest of the issues may benefit from waiting and hearing the EWG view, the At-Large Registration WG view + the At-Large IDN WG view, which will take time.

There will be calls for comments on the EWG work as well as the Translation Transliteration WG work in the future, so there will be future opportunities for providing input on the more complex aspects of the issue.

Best regards,

Rinalia On Feb 17, 2014 8:36 AM, "Carlton Samuels" < carlton.samuels@gmail.com > wrote:

...

FWIW, the specific issue of whether translations should be provided for registration data for directory services is under active discussion in the EWG.

-Carlton

============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround*

...

=============================

On Sun, Feb 16, 2014 at 1:20 AM, Rinalia Abdul Rahim < rinalia.abdulrahim@gmail.com> wrote:

...

Dear Olivier,

I believe the questions posed to SO/AC from the Translation Transliteration of Contact Information WG requires At-Large scrutiny beyond the IDN Working Group. The Registration Issues WG, among others, may have a view on some of the key issues.

The question of who should pay for translation and / or transliteration, for example, may implicate registrants. This question is linked to the purpose and benefit of contact data transformation, which is a higher level issue.

Best regards,

Rinalia Dear Staff,

I note the request for feedback. I think the format in which the request is made will deter responses. Specifically, the questions posed are buried in a PDF document and not highlighted for appropriate attention.

Action Needed: 1. Please lift the questions out of the mail from Glen and highlight prominently on the wiki page. 2. Please number the questions so that people can identify the ones that they are responding to and so that it would be easier to aggregate and analyze the response.

Thanks.

Rinalia

On Thu, Feb 13, 2014 at 9:35 AM, ICANN At-Large Staff < staff@atlarge.icann.org> wrote:

...

Dear Edmon and Rinalia,

Please note that the At-Large Translation and Transliteration of Contact Information Working Group SO-AC Input Request Workspace< https://community.icann.org/x/bgDRAg> has been created. Please note that this workspace will be used to gather the At-Large's comments on this Input Request

Please submit any comments on the workspace using the comments function by *28 Feb 2014 23:59 UTC*.

Regards,

Heidi Ullrich, Silvia Vivanco, Matt Ashtiani, Gisella Gruber, Nathalie Peregrine and Julia Charvolen

ICANN Policy Staff in support of ALAC

E-mail: staff@atlarge.icann.org

_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac

At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:

https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)

...

...

...

_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac

At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:

https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)

...

_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac

At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)

-- Evan Leibovitch Toronto Canada Em: evan at telly dot org Sk: evanleibovitch Tw: el56