Today we filed the attached comment on the Phase 2 Initial Report of the EPDP on Internationalized Domain Names (IDNs) (link<https://www.icann.org/en/public-comment/proceeding/phase-2-initial-report-of...> to comment page). Thanks to Ching Chiao for drafting. On 5/13/24, 10:35 PM, "Bc-private" <bc-private-bounces@icann.org> wrote: BC members, Thanks to Ching Chiao for drafting a BC comment (here<https://docs.google.com/document/d/1-iEoe3Mc3ReZH5W5U_cX-MSsS3a3eKNuMoiNnpQH...> and attached) on Phase 2 Initial Report of the EPDP on Internationalized Domain Names (IDNs) (link<https://www.icann.org/en/public-comment/proceeding/phase-2-initial-report-of...> to comment page). Thanks to Hafiz Farooq for volunteering as well. Here’s a summary of the draft: BC is in full support of the wider IDN.IDN adoption with the proper and orderly introduction of the variant domain names at the top and second levels. BC welcomes the IDN EPDP Team’s consistency on the “Same Entity” and “Conservatism” principles. We are glad to learn that the “Same Entity” principle is expanded as “same registrant, same registrar” which we’ve proposed in our previous comment on the Phase 1 report. The BC is however concerned that the IDN EPDP Team chose not to provide a clear recommendation to one key fundamental question in its draft report. The question is: Is an IDN.IDN variant domain a newly created, separated domain from its source IDN.IDNdomain? From BC’s viewpoint, we understand the current industry practice as the following definition in sequence: IDN.IDN (text) domain is equivalent to its XN-- . XN-- ( punycode) domain based on IDNA standards / IDN Guideline For example, the Chinese IDN.IDN (text) “亚马逊.购物” is converted to “xn--jlq480n2rg.xn--g2xx48c” in the DNS for actual domain resolution. IDN.IDN variant (text) domain is equivalent to its IDN.IDN source (text) domain as defined by the IDN language table maintained by the corresponding TLD registry (and approved by ICANN) as well as ICANN’s Root Zone LGR. For example, “亞馬遜.購物” (punycode “xn--nlqs61nl3f.xn--g2xv08c”)is the Traditional Chinese IDN.IDN variant of the source IDN.IDN ““亚马逊.购物” domain in Simplified Chinese. Therefore, if 1 and 2 must co-exist, it means that the IDN.IDN variant domain is not a separable, independent domain name registration from its source domain. Any existing and future variant domain name is in a parent-child relationship to its source domain. An IDNvariant.IDNvariantTLD domain names are generated / auto-generated by the TLD registry as derivative options to the same entity, and the variant or the variant set should not be independently created utilizing “EPP-create” transaction. Since activation of an IDN.IDN variant domain is not considered as a new-create, the registry / registrar therefore should not charge additional fee to its user. Comments close 21-May, so please bring up your questions and suggestions on our 16-May call, or on-list before 20-May. Thanks again to Ching for drafting.