I have been working on one of the IDN project groups (the Latin Generation Panel). As a result, I have seen some disconnects between what we are doing there and what is discussed in the presentation. Allow me to note a couple of issues I see: First, there are references (for example Slides 7 and 8) to "variants". At the Generation Panel, we are making decisions about what constitutes a variant. There is strong push from above to make the criteria as strict/narrow as possible, so as to keep the number of variants low. To the point of requests to remove some variant pairs which are truly indistinguishable, simple because the variant set is "too large". Most of the cases of characters (letters plus diacritics in our particular script, although there are also cross-script variants to consider) which are readily mistaken for each other are being relegated to "confusables". That is, characters with differences that a few sharp-eyed users will notice, even though the vast majority of users will not. For TLDs, there are apparently plans to have cases involving the latter manually evaluated. But whether they should be considered "variants" as the WG uses the term, or how else to identify them, is not obvious. Second, most of the discussion here involves TLDs. But there would seem to be an even larger potential for problems with SLDs. At the moment, decisions about what registrations of SLDs to allow and what to block are left entirely to the discretion of the individual registries. ICANN makes no requirement, either in the registry contracts or otherwise, restricting the use of variants (under whatever definition). There was discussion at Montreal of a recent problem involving someone registering a domain name which was identical to the name used by EasyJet, except that the J was replaced by an I. (The problem was eventually resolved by revoking the second registration.) Even though users are typically very familiar with both letters, there were a number of users who were successfully scammed by the second registration. How much easier would it be to sow confusion if the registration involved characters that most users are NOT familiar with? For example, a Small Letter I with Ogonek ( į ) occurs only in Lithuanian. Like a Small Letter J, it continues below the line -- making it substantially harder to spot as a substitution. easyįet.com is even easier to mistake for easyjet.com than easyiet.com was. For TLD registrations, attempted registration with only this difference would be blocked. But for SLDs, it would be available. And this is just one of dozens, perhaps hundreds, of opportunities for user confusion. Note also that ICANN will be publishing tables of variants (and confusables) whose use in TLDs is restricted. Those tables then become a resource for any bad actor looking for ways to create an SLD which will confuse users. My thought is that the registry contracts should be modified to require that SLDs which differ only by variants (and confusables) be blocked. Otherwise, we are looking at significant increases in the number of cases which, like with the EasyJet case, are only addressed after the damage has been done. Prevention seems like a far better way to go. Bill Jouris From: Justine Chew <justine.chew.icann@gmail.com> Date: Mon, 17 Feb 2020 at 14:26 Subject: Request for comments to IDN and UA preliminary scorecards in context to Subsequent Procedures To: IDN-WG <idn-wg@atlarge-lists.icann.org> Dear IDN-WG colleagues, Some of you will know that the At-Large Consolidated Policy Working Group (CPWG) is in the process of reviewing the anticipated recommendations (also affirmations and implementation guidance where available) of the New gTLD Subsequent Procedures PDP WG ahead of the release of its draft final report later this year. The process adopted by CPWG is to review a series of At-Large preliminary scorecards on various topics of high and medium priority from the end-users' perspective. It was agreed that assistance be sought from members of the IDN-WG on the preliminary scorecards for Universal Acceptance and Internationalized Domain Names, as both areas are considered key foci for the IDN-WG, given the expertise and interest of its membership. Thus, please find for comments the following: - Universal Acceptance draft preliminary scorecard as at 16 Feb 2020 (contains draft SubPro WG affirmations, recommendations & implementation guidelines) - Internationalized Domain Names draft preliminary scorecard as at 16 Feb 2020 Please bear in mind that while we welcome comments in general, the CPWG Small Team working to finalize and consolidate the scorecards in due course will attempt to do so by considering feedback which ought to be taken up (or re-taken up, as the case may be) versus which might be omitted. The format of the preliminary scorecards provide an idea on the Small Team's approach. We also suggest that you peruse the presentation setting out the status of SubPro WG deliberations against the ALAC's last public comment input as at 26 August 2019. Perhaps some consideration for these preliminary scorecards can factored into any planned face-to-face meeting at ICANN67. Many thanks in advance, Justine ------------------------------------------------------------ Justine Chew CPWG SubPro Small Team Lead At-Large liaison for Subsequent Procedures ------------------------------------------------------------