Dear colleagues,

I have added this Thai letter to https://community.icann.org/display/tatcipdp/List+of+correspondence+received . Please have a critical look at it and make any comments either before the meeting on this list or during agenda point 4: https://community.icann.org/display/tatcipdp/27+February+2014

I have added the two main questions (and sub-questions) from the charter for your convenience and for discussion under agenda point 5. We will be considering the prioritization of the questions.

Breaking difficult questions into several easier ones is only one possible working methodology and we are open to other approaches. Again, please make any comments either before the meeting or during agenda point 6.

Although at least one of the Study for the Submission and Display of Internationalized Contact Data’s surveys has been opened, they will be raised under AOB for any comments.

Regards,

Chris.

FYI

Dear GNSO Secretariat;

Reference made to your letter on 5 February 2014: Input Request: Translation and Transliteration of Contact Information Charter Questions.  On the role of our official position as the GAC Representative of Thailand to ICANN and  Deputy Executive Director of Electronic Transaction Development Agency, Ministry of Information and Technology, Royal Thai Government; and also the fact that  we had been participated as individual memberer in Charter Drafting Team of Translation and Transliteration of Contact Information PDP working group. We would like to give some thoughts and express our opinions on this issue for the Working Group as follow:

Input Request

Translation and Transliteration of Contact Information Charter Questions

Whether it is desirable to translate contact information to a single common language or transliterate contact information to a single common script.

The linguistic landscape of Thailand is often portrayed as monolingual and highly homogenous with government sources claiming that almost 100% of the population speak standard Thai (National Identity Board, 2000). As might be expected this hides a more complex linguistic picture. Other languages including Chinese, Malay, Lao, and Khmer are also spoken by minority groups (National Identity Board, 2000; Foley, 2005) and the majority of the population use one of the four regional dialects of Thai rather than standard Thai (Simpson and Thammasathien 2007).

Nevertheless, given the relatively minor status given to other languages in the country, English forms the ‘de facto’ second language of Thailand. There are a number of domains in which English is widely used in Thailand including: as a compulsory subject in school and in higher education, as a medium of instruction in international education programs, as the language of international organisations and conferences (including ASEAN and ASEAN +3), for international business transactions, tourism, the internet, global advertising, scientific and technology transfer, media (including imported films and music), international safety and international law(Wongsatorn et al 1996; 2003; Foley, 2005)”

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?

From the stated current condition, if the contact information needs validation, it could be a burden trying to figure out the suitable reference, if any. We have no objection with the approach from the Translation and Transliteration of Whois Contact Information DPD Working Group that this issue is tightly related to the role of government. Currently we are under the consideration to provide the infrastructure for translation and/or transliteration as the single registry system. This approach could benefit as in the most accurate reference for contact information in English and the validation could be handled at the most economic cost.

Should translation and/or transliteration of contact information be mandatory for all gTLDs?

We support that it should be mandatory. From the statistic, around one-third of the domain names in Thailand registered with ccTLD (.th) and anther two-third of the names are gTLD, which is open to all ICANN's registrars. Many cases that Thai domain owner registers for a domain name from foreign registrar, as the nature of internet is borderless. Not having translation and/or transliteration mandatory for all gTLD would create discrimination to registries and registrars.

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?

What impact will translation/transliteration of contact information have on the WHOIS validation as set out under the 2013 Registrar Accreditation Agreement?

Reference to section: Whois Accuracy Program Specification §1(e),

"Validate that all postal address fields are consistent across fields (for example: street exists in city, city exists in state/province, city matches postal code) where such information is technically and commercially feaible for the applicable country or territory."

Reference to section: Whois Accuracy Program Specification §1(f) and §2

"if Registrar does not receive an affirmative response from the Account Holder, Registrar shall verify the applicable contact information manually"

It occurs in Thailand that more than half of the domain name owners using gTLD and it is possible to choose foreign Registrars. The manual verification might occur when registrar does not receive an affirmative response via email or phone. Even it is not specified the method, this manual verification could costly for Registrar when it is cross-border verification.  This also emphasizes the need of single point of registration system for common language/script of contact information for each country. To minimize any cost that might occur during verification, and the more important point is to provide the eligible contact address information.

When should any new policy relating to translation and transliteration of contact information come into effect?

(Reference: http://docs.apwg.org/reports/APWG_GlobaTolPhishingSurvey_1H2013.pdf)

Thailand has been, disappointedly, in the top-5 of phishing for the past several years. From our view, we see that having translation and transliteration pocily in place would be one of the phishing mitigations as the verified contact information would be the important eligible linkage between internet identities to the real person. We encourage that this policy should come into effect at the earliest possible timeline.

Do you have suggestions concerning the basic principles to guide the cost burden discussion, such as the free of charge provision of the information, demand-oriented cost etc.?  In particular, the PDP WG is tasked with determining 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.

In compliance with the "Proposal by THAILAND’s Government Advisory Committee (GAC)" submitted into the PDP working group earlier, it is government role to facilitate establishment of the infrastructure for translation/transliteration of contact information. Once the infrastructure is in place, the cost of translation/transliteration and the cost of validation should be economic. This eligible registered contact address information will also be applicable for many other applications for data owner, not limited to ICANN whois database but it could also benefit the e-invoice and all electronic transaction services.

We would suggest considering demand-oriented approach for this matter. In this case, the demand to translate/transliterate and maintain contact address information is belong to the data owners or registrants, and the demand for address validation could be from registrars. Therefore, the cost of conversion from local language into common language should belong to registrants and the cost for validation should belong to registrars.

We are looking forward to gather for a face-to-face meeting during the ICANN Meeting in Singapore.

Regards

Mr. Wanawit Ahkuputra

Deputy Executive Director

ETDA Electronic Transactions Development Agency (Public Organization)

MICT Ministry of Information and Communication Technology

The Government Complex Commemorating His Majesty the King's 80th Birthday Anniversary

120 M.3 Ratthaprasasanabhakti Building (building B),

7th floor, Chaengwattana Rd., Thung Song Hong,

Laksi Bangkok 10210, THAILAND

Tel : +66 2142 1159

Fax. +66 2143 8071

Mobile +669 301 8818

E-Mail: wanawit@etda.or.th