Dear all, The ALAC Team respectfully submits that both the phrases "consistent user experience" and "usability goal" are inspired by the Charter of the EPDP on IDNs. The phrase "security and usability goals" appears four times in the Charter, and the phrase "good user experience" once. In particular, the Preamble states that: This EPDP is expected to provide the GNSO Council with policy recommendations on: i) the definition of all gTLDs and the management of variant labels to facilitate the delegation of variant gTLDs in the root zone while achieving the *security and usability goal of variant labels in a stable manner*; and ii) how the IDN Implementation Guidelines, which Contracted Parties are required to comply with, should be updated in the future.
From this, it appears to us that security, stability, and usability are all important goals. Since Recommendation 2.6 states that the applicant will be “required to demonstrate their ability to manage the primary IDN gTLD and the applied-for variant label(s) as a set from both a technical and operational perspective”, we believe that the Rationale should refer to these goals.
Accordingly, we propose the following formulation for Implementation Guidance (new) and Rationale for Recommendation 2.6 where our proposed edits are marked in blue text, while the pink text indicates the current edits that are being considered. The proposed Implementation Guidance xx is borne out of Dennis' comment for clarity with respect to the last 2 sentences in the Rationale. The Recommendation itself is unchanged and is provided for completeness. *Recommendation 2.6:* The applicant will be required, as part of the application process, to explain the reason(s) why it needs to activate the applied-for variant label(s). In addition, the applicant will be required to demonstrate their ability to manage the primary IDN gTLD and the applied-for variant label(s) as a set from both a technical and operational perspective. Implementation Guidance xx: Submission by applicants of supporting information must allow for a consistent and meaningful evaluation by evaluators with the requisite expertise. Rationale for Recommendation 2.6 and Implementation Guidance xx: 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. ThereforeConsequently, 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 to achieve the security, stability, and usability goals for their set in a stable manner. This would contribute to ensuring a good user experience. IDN variants 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. In other words, we are proposing that the Recommendation, Implementation Guidance, and Rationale read as follows, *Recommendation 2.6:* The applicant will be required, as part of the application process, to explain the reason(s) why it needs to activate the applied-for variant label(s). In addition, the applicant will be required to demonstrate their ability to manage the primary IDN gTLD and the applied-for variant label(s) as a set from both a technical and operational perspective. Implementation Guidance xx: Submission by applicants of supporting information must allow for a consistent and meaningful evaluation by evaluators with the requisite expertise. Rationale for Recommendation 2.6 and Implementation Guidance xx: 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. Consequently, 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 to achieve the security and usability goals for their set in a stable manner. This would contribute to ensuring a good 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. With kind regards satish