Dear all

The ALAC Team has the following comments and questions vis-à-vis SAC060 and SSAC2021-09. These are limited to Part A charter questions, and we understand that SSAC members will be invited again to discuss other parts of their early input when the EPDP Team considers the rest of the charter questions.

SAC060 Recommendation 14 says, “ICANN should ensure that the number of strings that are activated is conservative”; and goes on to rationalize that:

“Variants introduce a permutation issue both at top level as well as with combinations of the top level and second level”, giving the following example:

A TLD string with 4 char with 3 variants each, produces a variant set of 81 different strings (3^4 = 81)
An SLD (under such above TLD) with 4 char with 3 variants each, produces a variant set of 72,171 different strings (3^4 x 3^4 = 72,171)

and that "[s]uch a large number of variant strings present challenges for management of variant domains at the registry, the registrar and registrant levels."

Question #1: Could the authors please elaborate, by using a theoretical example, on the nature of the challenges in managing variant domains at registry, the registrar and registrant levels?

In agreeing with the user experience report recommendation that ICANN must implement a conservative variant TLD allocation process, SSAC suggests:

In SAC060, that “A variant TLD application must be accepted only if the TLD applicant clearly demonstrates the necessity for activating the string. Variants that are not necessary, but are desired, must not be allocated and activated” and
In SSAC2021-09, that “..there should be a mechanism to ensure that the number of delegated top-level variant labels remains small. Unless there is demonstrated widespread usage of the variant label, the variant label should not be activated.”

Question #2: Could the authors please suggest criteria for or provide examples of what constitutes a demonstration of “the necessity for activating the string” or “widespread usage of the variant label”?

With kind regards

satish

On Mon, Jan 10, 2022 at 3:42 AM Donna@registry.godaddy <Donna@registry.godaddy> wrote:

Thanks Jeff, your 1. Below may need a rewrite.

A reminder to others that it would be great if we could get your questions by cob Monday 10 January (UTC 23:59)

Thanks

Donna

From: Gnso-epdp-idn-team <gnso-epdp-idn-team-bounces@icann.org> On Behalf Of Jeff Neuman
Sent: Saturday, January 8, 2022 6:26 AM
To: Emily Barabas <emily.barabas@icann.org>; gnso-epdp-idn-team@icann.org
Subject: Re: [Gnso-epdp-idn-team] Deadline 10 January: Provide questions for SSAC members

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Here are my questions based on SSAC 60

SAC060 notes that variant code points in LGR may Introduce a “permutation issue”, possibly creating a large number of variant domain names, which “presents challenges for the management of variant domains at the registry, the registrar and registrant levels.”

SAC060 advises that “ICANN should ensure that the number of strings that are activated is as small as possible.

Questions

1. Although this advice sounds standing sounds like it is sensible:

a.           How can this practically be implemented?

b.           What does “As small as possible” really mean?

c.           Who determines what is “as small as possible” means?

d.           What is a number that would be anything other than arbitrary?

2. According to the Rationale, it appears that the SSAC is presenting this advice to protect registries, registrars and registrants from themselves. In other words, the advice assumes that registries, registrars and registrants will want to activate more strings than they would be able to handle.

a.           Normally all policy starts from the basic presumption that each of the actors involved will act in a rational manner and in their own best interests. This is the basis of all business and economic theory. But this policy recommendation takes the opposite view and starts from the premise that registries, registrars and registrants will essentially try to activate more than they can handle and thus we need to protect them from themselves. Is there any evidence upon which that assumption is based?

b.           Given no proof that registries will intentionally activate more strings than they can handle, should we really be placing any artificial limits?

c.           Assuming we either have or do not have a limit, how do we determine when a registry, registrar or registrar has more challenges than they can handle? What do we do? Is this really an ICANN problem?

d.           Finally, given all of the above, shouldn’t we allow registries, registrars and registrars figure out what it is that they can handle as opposed to placing an arbitrary limit?

Jeffrey J. Neuman

Founder & CEO

JJN Solutions, LLC

p: +1.202.549.5079

E: jeff@jjnsolutions.com

http://jjnsolutions.com

From: Gnso-epdp-idn-team <gnso-epdp-idn-team-bounces@icann.org> On Behalf Of Emily Barabas
Sent: Thursday, January 6, 2022 2:23 PM
To: gnso-epdp-idn-team@icann.org
Subject: [Gnso-epdp-idn-team] Deadline 10 January: Provide questions for SSAC members

Dear all,

As discussed on today’s call, EPDP Team members are requested to draft specific questions they would like to ask SSAC members on the 13 January call.

For reference, you can find the early written input from SSAC members here.

Kindly respond to this message with your questions for SSAC members no later than Monday, 10 January.

Kind regards,

Ariel, Steve, and Emily

Emily Barabas

Policy Development Support Senior Manager

Internet Corporation for Assigned Names and Numbers (ICANN)

Phone: +31 (0)6 84507976

www.icann.org

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