Ariel, et al On behalf the RySG members of the EPDP I would like to submit the following observations to the draft outcomes. * Summary of the redline: Adding clarifying language to reflect that allocation alone of a TLD to a same entity cannot guarantee avoiding denial of service failure mode. * Proposed language: Rationale for Recommendation 2.1: To support its consideration of charter question B1, the EPDP Team reviewed the SubPro PDP recommendation 25.5 and Staff Paper recommendation 2, as well as their rationale. The EPDP Team agreed that abiding by the “same entity” principle and having the same registry operator for all allocatable variant labels of an existing gTLD will help minimize, but not guarantee, the security risk associated with the “failure modes” – including denial of service and misconnection – when dealing with variant labels. Therefore, the EPDP Team affirms to extend the SubPro PDP and the Staff Paper recommendations to existing gTLDs. * Why the redline? Recommendation 2.1 is applied at the top level, not at the domain name level. Making a TLD label allocatable to a single entity (or withheld) does not directly avoid the failure mode of denial of service. Even if the gTLD variant is activated into the root, an actual domain name (second level.variantTLD) needs to be registered and operated, in all variant TLDs. So, while it can help to minimize denial of service problem, it cannot guarantee it due to downstream actions (by other entities different than the registry operator) that need to be implemented. Therefore, the inclusion of a caveat. Related to this. For special purpose TLDs (brand, geo, community based) if the variant set is held to the same requirements, then it is possible that allocatable variants do not meet the same eligibility requirements as the primary label (for example, a trademark record). Avoiding denial of service due to an inactive TLD variant (in this case) is not only improbable, but impossible. * Summary of the redline: a registry operator should not be expected to ensure consistent user experience because it does not host or manage content (e.g. website, email services). * Rationale for Recommendation 2.6: As IDN gTLDs and variant labels that are considered a set are yet to be delegated and operated at the root zone level, there is uncertainty about how the set will be managed and operated by the registry operator from a technical and user perspective. Therefore, it will be important that applicants are able to explain their need for a set of IDN variant label(s) as well as demonstrate their technical capability to operate and manage the set. Therefore, the applicant will be required to respond to additional application questions to address why they seek to activate those variant label(s) in addition to the primary new gTLD (i.e., necessity and expected usage of the variant labels), as well as how it plans to manage the set operationally, with a view to ensuring a secure, stable, and consistent user experience. The applicant’s response to these questions is expected to be a critical component in the evaluation process. Evaluators with requisite expertise are expected to assess these responses. * Why the redline? While the language is in the rationale and not the draft recommendation, it may be misconstrued in an implementation guideline. We are far away from discussing operational requirements, but the suggestion that a registry operator should be expected to “manage” and “ensure” a “consistent user experience”, we think it may be misleading. We suggest removing that sentence from the rationale which does not affect the overall intent. * Summary of the redline: Minor change for consistency in terminology. * Recommendation 2.3: If the registry operator operating a variant gTLD label changes its back-end registry service provider, all the variant gTLD label(s) in the set must also switch transition to the same new back-end registry service provider. * Why the redline? Harmonizing language with MSA change process<https://secure-web.cisco.com/17PTWZSoYgDuVsWnubBEirA3cdXcqCb3xaJvHUco0vIFE1J...>, which uses the term “transition”. One additional note. On draft recommendation 2.8 (B5: special purpose TLDs) I have shared the draft outcome with our colleagues in the Brand Registry Group and GeoTLD Group. I’m working with them to get their insights, so I’d like to ask for your patience while I compile their input. Thank you, Dennis, on behalf the RySG IDN EPDP members From: Gnso-epdp-idn-team <gnso-epdp-idn-team-bounces@icann.org> on behalf of Ariel Liang <ariel.liang@icann.org> Date: Thursday, July 14, 2022 at 12:04 PM To: "gnso-epdp-idn-team@icann.org" <gnso-epdp-idn-team@icann.org> Subject: [EXTERNAL] [Gnso-epdp-idn-team] Reminder: Draft Outcome: Group 2 Charter Questions Related to "Same Entity" Principle at Top-Level Caution: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear All, This is the final reminder for reviewing the draft outcome language for Group 2 charter questions by EOB Friday, 15 July (initial deadline extended by one week). Please see details below. FYI - the ALAC Team informed staff that they agree with the draft language for those questions. Best Regards, Ariel From: Ariel Liang <ariel.liang@icann.org> Date: Friday, June 24, 2022 at 11:43 AM To: "gnso-epdp-idn-team@icann.org" <gnso-epdp-idn-team@icann.org> Subject: Draft Outcome: Group 2 Charter Questions Related to "Same Entity" Principle at Top-Level Dear All Please find the draft outcome language for Group 2 charter questions related to “same entity” principle at the top-level, which are: · B1, B2, B3, B5: https://docs.google.com/document/d/15YGISgNQYL_VfcVVZ6E97qbo42GPziP6x089bR3w... · D1a, D1b (Part 2): https://docs.google.com/document/d/1C6xKX87w2LtN4Is0mehuRgc1GqjKmbbhT14KbvUH... Both documents are also posted on the wiki page here: https://community.icann.org/x/XwyHCg<https://secure-web.cisco.com/1cLkZefuhXu_uH3vPKV-WqdDsF3bAzHFSuVy6oxj5LpOcybpNP4PyqXxwdzXfKE839qWUKiXL4Tac845XODFW9zsz-2JTwMygfJszPmKDuLAJup98RKhMiPeOff-kGqgdD4cKTDFD7L0B-9HvQoE_fGIjrTbxPFuTcTETGelO62_PEs9hq2SqTx0oyTv21YDmCba0hl6L1fsggbDua02iAwynycwUCw8SQ3boexaJTHDEqxtRlrTNkmGmyoakpGkF/https%3A%2F%2Fcommunity.icann.org%2Fx%2FXwyHCg>. Following the agreed format, the draft outcome language includes the following components: · Brief answer to the charter question · Recommendations and implementation guidance · Rationale for recommendations and implementation guidance Please note that for charter question D1b Part 1 (related to the process by which an existing TLD registry operator seeks to activate variants) has not be addressed; it depends on the survey responses from the Arabic/Chinese TLD ROs. Please provide any input/suggestion for the draft outcome language on the mailing list by Friday, 8 July. Best Regards, Steve, Emily, Ariel