Please find my comments on the Technical Utilization of the RZ-LGR, as published at https://www.icann.org/en/system/files/files/recommendations-rz-lgr-14may19-e... My comments are provided as an individual. Regards, Marc Blanchet ============================================= section 3.2: Self-identified variants are to my knowledge not being delegated. Therefore, they should not be taken into account. Instead, the RZ-LGR should be the only normative source of variants. section 4.1: in this context, IDNA2008 is not enough precise. IDNA2008 provides rules that are applied to Unicode properties. Therefore the assessment of if a code point is DISALLOWED or UNASSIGNED depends on which Unicode version it is applied. History has shown that new Unicode versions may not automatically be applied. Suggested modification of text: « An applied-for label containing any DISALLOWED or UNASSIGNED code point(s) per IDNA 2008 applied to the most recent supported Unicode version, at the time of the verification, or its successors, must not proceed. » section 5: Option B. I strongly disagree in opting for Option B. Option B is trying to replicate the Procedure while not really doing it. Experience of past and current work of GPs and IP have shown how much complex can be the study of scripts repertoire and variants, including complex rules. Cross-script interaction is also key to this assessment. The cross-script study can only be done in a consistent way by people looking at the whole process and all the scripts, not by a restricted set of people familiar with the script being studied. Moreover, Option B is in some ways bypassing the whole process of the procedure. Finally, by not looking at the whole problem space, Option B may bring incompatible labels for the future script LGR. Option B must not be considered. section 6. While the SG may have decided to punt the issue of the number of delegated variants, it remains a very significant potential problem that should be undertaken. If no recommendation about this issue is agreed with the community, then we may end up later with applicants asking for a large number of variants, which will have way too many implications in security, in deployment, in software, … We have to remind ourselves that, in general, tools to manage and use variants in the DNS do not really exist. This issue has to be undertaken, soon. multiple sections: It should be noted that the RZ-LGR consists of multiple XML files, or is an XML files set. Current writing in many places imply a single XML file. nits: section 10. The reference is misplaced. As it is, it seems to say that the IANA authoritative files are provided by the toolset. Instead of « but as a tool for community service. Only the XML file of the RZ-LGR published by PTI/IANA is to be considered authoritative or normative.[10] » , the suggested modification would be: « but as a tool for community service[10]. Only the XML file of the RZ-LGR published by PTI/IANA is to be considered authoritative or normative. »