Dear IDN Working Group Members and ALAC Colleagues, In response to the ICANN Board's request for guidance on the implementation of IDN Variant TLDs as well as the release of the “IDN Variant TLD Program - Risk Analysis Studies” dated May 2013, Edmon and I have developed a draft statement for the ALAC's consideration. Text of the drafted statement is pasted below. WIKI Page for your comments is located here: https://community.icann.org/display/alacpolicydev/ALAC+Statement+on+the+Impl... Please try your best to provide your comments via the wiki by June 16th. Best regards, Rinalia *ALAC Statement on the Implementation of IDN Variant Top Level Domains * *[Version 10 June 2013]* The ICANN Board has requested guidance from the community regarding the implementation of the Recommendations contained within the Report on User Experience Implications of Active Variant TLDs ( http://www.icann.org/en/groups/board/documents/prelim-report-11apr13-en.htm#...). After reviewing the Report as well as the “IDN Variant TLD Program - Risk Analysis Studies” dated May 2013, the At-Large Advisory Committee (ALAC) advises the following: *Introduce IDN Variant TLDs carefully and implement complementary IDN policies concurrently * - Facilitate the introduction of IDN Variant TLDs carefully so as to nurture growth of the IDN market. The successful implementation of the initial set of IDN TLDs and IDN Variant TLDs will create higher visibility for IDNs and can be expected to stimulate further demand. - The prioritized implementation of IDN new gTLDs must be accompanied with the concurrent execution of complementary and enabling policies, specifically: - Implementation of policies that support the Universal Acceptance of IDNs, - Implementation of IDN Variant TLDs; and - Inclusion of IDN variant support in the Trademark Clearinghouse (TMCH). * * *Bundle the delegation of TLDs and variant TLDs appropriately* - In cases where variants are well defined and understood, and where they are essential for the communication needs of user communities, IDN Variant TLDs must be delegated together with IDN TLDs to ensure consumer trust among the implicated user communities. - Concurrently, variant support in the Trademark Clearinghouse (TMCH) must be included in time to accommodate the delegation of appropriate TLDs to address the issues of user confusion as well as effective trademark protection. *Prepare user communities via dedicated outreach* - Release appropriate educational materials and conduct awareness-raising initiatives widely on the use and impact of variants on different user communities well in advance of IDN Variant TLD delegation. - These outreach efforts should target IDN users as well as non-IDN users to address any trust issues that they may have. See the following as an example of research findings indicating the need for more education and awareness-raising about IDNs in developed economies - http://www.domainnews.com/en/afilias-research-75-of-uk-and-us-consumers-obli... . *Demonstrate a strong commitment to multilingualism * The introduction of IDN Variant TLDs is a policy choice, which requires the strong commitment of ICANN and the ICANN community to multilingualism. The competing perspectives between the technical (conservative) and linguistic (comprehensive) communities need to be balanced carefully within an overarching commitment to multilingualism. A demonstrated commitment to multilingualism will encourage collaboration between the two communities in finding workable solutions and common ground in introducing IDN Variant TLDs without undermining the security and stability of the Domain Name System. *Expedite the implementation of the Root LGR process * - Expedite the implementation of the Label Generation Rules (LGR) process for the Root Zone to address the risks that have been identified in the “IDN Variant TLD Program - Risk Analysis Studies.” - Ensure that lack of expertise is not a reason for delaying or prolonging the implementation of the process. The inadequate supply and availability of the right kind of experts have been identified as a possible bottleneck for the Root LGR process. We note that a call for subject matter experts has been issued on 6 June 2013. Should the response prove to be inadequate, measures would be required to seek expertise outside of the ICANN community. - Expedite the delivery of the Han script ruleset in the Root LGR process. Among all the writing systems studied by ICANN in the IDN Variant Issues Project* (*VIP), the Han script variants are the most well defined and understood. ICANN experts (Andrew Sullivan and Asmus Freytag) concurred during the ICANN 46th Meeting in Beijing that the Han script is possibly the only exception in this regard. * * *Involve the community in the governance of the Root LGR Process* Involve the ICANN community (Supporting Organizations and Advisory Committee) in the implementation planning and delivery of IDN Variant TLDs as well as in the governance oversight of the Label Generation Rules (LGR) for the Root Zone process, which is crucial for deriving a comprehensive and consistent treatment for variants across the board. In particular, - Ensure that the LGR process is accountable and transparent. - Address its weaknesses (i.e., the lack of a review and appeals process, insufficient supply and availability of experts as well as mechanisms for avoiding capture) - Address the weaknesses of the ICANN Public Comments process (a core feedback mechanism for the LGR process) to enable a more open and meaningful stakeholder participation. The ALAC’s advice as indicated above is consistent with the following statements that we have issued regarding IDNs and IDN Variants: - ALAC Statement on Trademark Clearinghouse and IDN Variants - ALAC Statement on IDN Variant TLD Program – Interim Report Examining the User Experience Implications of Active Variant TLDs<https://community.icann.org/download/attachments/2261148/ALAC%2BStatement%2B...> - ALAC Statement on the IDN Variant TLD Program – Procedure to Develop and Maintain the Label Generation Rules for the Root Zone in Respect of IDNA Labels<https://community.icann.org/display/alacdocs/ALAC+Read+Only+Document+Store>- Second Public Comment Draft - ALAC Statement on the IDN Variant TLD Program – Procedure to Develop and Maintain the Label Generation Rules for the Root Zone in Respect of IDNA Labels<https://community.icann.org/download/attachments/2261148/ALAC+Statement+on+t...> - ALAC Statement on the Draft Recommendations Overall Policy for the Selection of IDN ccTLD Strings<https://community.icann.org/display/alacdocs/ALAC+Read+Only+Document+Store> - ALAC Statement on the IDN Prioritization in the New gTLD Program Targeted at the ICANN Board<https://community.icann.org/download/attachments/2261148/ALAC+Statement+on+t...> - ALAC Statement on the Internationalized Domain Name (IDN) Variant Issues Project (VIP) Proposed Project Plan for Next Steps<https://community.icann.org/download/attachments/2261148/ALAC+Statement+on+t...> END