Dear Colleagues, A draft ALAC statement has been posted on the Charter questions posed by the Translation and Transliteration of Contact Information Working Group on this wikipage: https://community.icann.org/display/alacpolicydev/At-Large+Translation+and+T... The draft is provided as a basis for discussion. Please note that you need to log-in to enable the comments feature of the wikipage. If you cannot log-in for whatever reason, please send your comments to staff ( staff@at-large.icann.org) and they can help you. The draft statement is pasted below for a quick review so that you can decide whether or not to comment via the wiki. Best regards, Rinalia *(DRAFT) ALAC Statement on Translation and Transliteration of Contact Information in Response to Working Group Input Request from SO/AC* (Note: The use of the word "transformation" of contact information pertains to the "translation and / or transliteration" of contact information.) *(1) Whether it is desirable to translate contact information to a single common language or transliterate contact information to a single common script* It is important to note that translating contact information to a single common language privileges the users of that language over other users, just as the transliteration to a single common script privileges users of that particular script over others. The choice of one single common language or script does not reflect or support a global Internet community, which is diverse in language and script use. Our preference is to have registration contact information in languages and scripts that reflect the diversity of Internet users. We believe that it is unreasonable to assume that registrants will be able to enter contact information in scripts or languages other than their local script and language. It is possible that some registrants may have the ability to do so, but in principle registrants should not be expected or required to transform their own contact information. In terms of the choice of whether to translate or transliterate contact information, the transformation of contact information to a level where it is understandable to users of registration data may require a combination of both. For example, when transforming contact information, proper names or nouns (i.e., unique names of persons, places, events and things) should not be translated and should instead be transliterated. *(2) What exactly the benefits to the community are of translating and/or transliterating contact information, especially in light of the costs that may be connected to translation and/or transliteration?* The Internet has a global user base. Transformed contact information that is validated to be accurate and useable allows users worldwide to see who are the domain name registration holders and how to contact/reach them. Contact information is used for various purposes by a range of users. The purposes include regulatory/contract enforcement, domain name monitoring and research, domain name purchase/sale, individual Internet use, technical issue resolution, legal action, abuse mitigation and malicious Internet activities (see Expert Working Group on gTLD Directory Services Report). In cases where harmful Internet activities are perpetrated, the availability of transformed contact information that is accurate and useable facilitates those taking action to protect end users. Moreover, transformed contact information that is validated for accuracy and usability promotes consumer trust in the Domain Name System and is beneficial to the At-Large community. *(3) Should translation and/or transliteration of contact information be mandatory for all gTLDs?* Based on the principle that gTLDs serve global Internet users, transformation of contact information should be mandatory for all gTLDs. *(3) Should translation and/or transliteration of contact information be mandatory for all registrants or only those based in certain countries and/or using specific non-ASCII scripts* If transformation of contact information is to be implemented as a matter of policy, then it should be mandatory for all registrants for the purpose of serving global Internet users. Registrants based in countries and / or using specific non-ASCII scripts should not be discriminated against in the implementation of contact data transformation. Contact information for registrants in ASCII script should also be equally transformed for the benefit of non-ASCII script users. *(4) What impact will translation/transliteration of contact information have on the WHOIS validation as set out under the 2013 Registrar Accreditation Agreement?* No comment. *(5) When should any new policy relating to translation and transliteration of contact information come into effect?* No comment. *(6) Who should decide who should bear the burden translating contact information to a single common language or transliterating contact information to a single common script? This question relates to the concern expressed by the Internationalized Registration Data Working Group (IRD-WG) in its report that there are costs associated with providing translation and transliteration of contact information. For example, if a policy development process (PDP) determined that the registrar must translate or transliterate contact information, this policy would place a cost burden on the registrar.* The decision on who should bear the burden of transforming contact information should be informed by the views of and impact on all affected parties, which would include the provider of the information (registrants), those involved in collecting and maintaining the information (i.e., registrar, reseller, registry) and the range of users that include end users and regulatory authorities/law enforcement agencies. The PDP decision-making rules and procedures for Consensus Policy should apply with input from all ICANN Advisory Committees (i.e., At-Large Advisory Committee, Governmental Advisory Committee and Security and Stability Advisory Committee). *(7) Who does your SG/C believe should bear the cost, bearing in mind, however, the limits in scope set in the Initial Report on this issue?* In determining who should bear the cost, it would be important to consider whether the transformation of contact information is made for general use or specialized use. If the transformation is required for general use, the cost should be borne by the process/entities that collect the information. If the transformation is required for specialized use, the parties requiring the specialized service should bear the cost of contact information transformation. If transformation has general use and is crucial for particular specialized use, then a sharing of costs between those collecting the information and those requiring specialized use of the information could be considered. END