Dear IDN WG and ALAC, Please find below the revised statement on the* "Draft IDN ccTLD String Selection Criteria, Requirements and Processes Policy Recommendations" *that incorporates additions proposed during the Toronto meeting. Suggestions for further amendments *must be received by Friday (November 2nd)* for the ALAC to commence a vote in time to meet the Reply Period deadline on November 9th. Thanks. Rinalia Abdul Rahim* * ** * * * * *ALAC Statement on the Draft IDN ccTLD String Selection Criteria, Requirements and Processes Policy Recommendations* The At-Large Advisory Committee (ALAC) commends the International Domain Names (IDN) country code Policy Development Process Working Group 1 for the comprehensiveness of its draft policy recommendations on the IDN ccTLD String Selection Criteria, Requirements and Processes for territories listed in the ISO 3166-1 list. We note that the recommendations are based on the previous work of the IDNC Working Group and we are pleased to see that the recommendations reflect the learning drawn from the implementation of the IDNccTLD Fast Track Process over the past few years. We observe that the draft recommendations do not address the issue of variant TLDs and instead contain a placeholder in Section J, which points out that issues pertaining to the management of such TLDs are still being discussed in the ICANN community and will be added later. We believe that the draft recommendations should indicate that the issue of variants is urgent and need to be addressed in a timely manner. Concurrently, the draft recommendations should also affirm that the outcomes of the variants discussion pertaining to the Label Generation Ruleset (LGR) for the Root Zone would be binding and applicable to all TLDs (including ccTLDs), given that the overarching principle of the LGR process is the security and stability of the Root Zone, which is shared by all Internet users. We note with concern that the draft recommendations consider selected IDN ccTLD strings to be confusingly similar based on their appearance to “a reasonable Internet user who is unfamiliar with the script” although "linguistic, technical, and visual perception factors" will be taken into consideration. Notwithstanding the merit and rationale for this assessment criterion, an assessment on confusing similarity based primarily on the appearance of selected strings to users unfamiliar with the script may not be consistent with the nature and purpose of IDN ccTLDs, which are fundamentally introduced for the use and benefit of local IDN users in pertinent ccTLD territories. Without taking into account sufficient linguistic factors, problematic results may occur. For example, an IDN ccTLD that is assessed as not confusingly similar by a user "who is unfamiliar with the script" may well be deemed confusingly similar by the local IDN user and vice versa. We believe that this particular issue can be addressed in the policy making process through more consultations with the IDN communities in implicated ccTLD territories. Finally, we wish to reiterate the significance and importance of IDNs, including IDN Top Level Domains (TLDs) at both the generic and country code levels. IDNs are crucial for enhancing diversity and multilingualism on the Internet. Towards this end, the attribution of IDNs should take into account the fact that some languages have a wide geographical distribution that go beyond national borders and are thus not the sole property of one sovereign state alone. It follows, therefore, that due consideration should be given to protecting the rights of concerned language communities which, though falling outside the jurisdiction of one nation state, share with its inhabitants a common language or script. END