Dear Kal, All,

The communication was forwarded to IDN Guidelines WG when it was received (see attached email).  This comment is in continuation of the comment submitted by JPRS during the public comment.

The WG had a discussion around the input received by JPRS at multiple meetings.  The final discussion took place on 19 April and the changes proposed were reviewed and agreed on 26 April (see notes at https://community.icann.org/display/IDN/IDN+Implementation+Guidelines). The summary of the discussion and changes to incorporate the JPRS feedback is as follows:

1. The WG discussed that changes should be made in Guideline 15 and not 16. 
2. The WG considered that the use of “script” is ambiguous and so changed the text to refer to “Unicode script” as defined in the Unicode script property. 
3. In the context of “unicode script”, Japanese writing system uses Hiragana, Katakana and Han. Therefore, the WG agreed to qualify Japanese case as a known exception of script mixing.  However, it was agreed that this be done as an Additional Note and not in the text of the guideline (latter to remain generic).
4. Additional Note V was added and says that Japanese is a known case where Hiragana, Katakana and Han scripts are mixed.   It also notes that Chinese, Japanese and Korean IDN tables also mix “a-z” ASCII. 
5. Additional Note VII allows additional letters like digits and hyphen to be mixed in scripts, where relevant.

The Additional Notes V and VII added are covering the concerns raised by JPRS to pre-qualify script-mixing in Japanese writing system.  It still puts the Japanese case in the “exception” category because the point of reference is the “Unicode script”, which the JPRS had suggested be reviewed.  The WG considered it and decided to use the “Unicode script” so that part of the comment was perhaps not addressed per the expectation of the JPRS.  Also, there are two separate guidelines – no. 14 for within-script cases and no. 16 for cross-script cases.  Therefore, no. 16 was not altered.

Please let me know how you would like to proceed.

Regards,
Sarmad

From: Idngwg [mailto:idngwg-bounces@icann.org] On Behalf Of Kal Feher
Sent: Friday, May 11, 2018 9:50 PM
To: idngwg@icann.org
Subject: Re: [Idngwg] FW: [Ext] haven't received any response from you

Hello Sarmad,

I don't recall the communication. Was it discussed in one of our meetings and were there any action points from that discussion that we have failed to take?

On 11/5/18 10:37 pm, Sarmad Hussain wrote:

Dear All,
 
We received the following communication from JPRS today.  Please let us know
how you would want to respond to it.
 
Regards,
Sarmad
 
 
-----Original Message-----
From: yoshitaka@jprs.co.jp [mailto:yoshitaka@jprs.co.jp] 
Sent: Friday, May 11, 2018 2:49 AM
To: Mats Dufberg <mats.dufberg@iis.se>
Cc: Sarmad Hussain <sarmad.hussain@icann.org>; Pitinan Kooarmornpatana
<pitinan.koo@icann.org>
Subject: [Ext] haven't received any response from you
 
Dear IDN guidelines WG Chair,
(CC: Sarmad、Pitinan)
 
On 30 March, I sent you our proposed change on the IDN implementation
guidelines document, following the suggestion made in the WG public meeting
in San Juan on 12 March (pasted below). For these one and half months, I
have not received any response to that from you.
 
Today, I happened to find that "Final Proposed Draft v. 4.0 of the IDN
Guidelines"
https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_news_anno
uncement-2D2018-2D05-2D10-2Den&d=DwICJg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms
7xcl4I5cM&r=KTETvEaGPwPcawI-QmNa-kiv-ZBvdgyyLm-mxd028M4&m=zptC-TxcZW1PmY1jJ5
LzXVqPvD3ZlsiKvb4agfECycQ&s=wxk9m-mdZnan6Q2PmV36GLfLEXk6eKFuZRXMIFdZLeg&e=
was published. 
 
It was a surprise and disappointing for us to find it without prior
correspondence regarding our proposal sent to you on 30 March.
 
Yoshitaka Okuno
Manager, Services Development Department Japan Registry Services Co., Ltd.
 
 
On Fri, 30 Mar 2018 17:40:59 +0900
yoshitaka@jprs.co.jp wrote:

Dear IDN guidelines working group,
 
Please refer to the following comments and proposal.
The comments and proposal are being sent to you, following your 
suggestion made in IDN Guidelines Working Group meeting in San Juan.
 
In the working group meeting, the essence was orally stated by Hiro 
Hotta, JPRS in the meeting room.
 
I hope this may be of help to you.
 
 
[Summary]
 
1. As described in current guidelines, the issues of visually confusable
   characters are not specific to the cases with commingled use of 
   multiple scripts.
 
   We believe Japanese domain labels fall on the exceptional cases 
   stated in Guideline#15.
   Kanji, Hiragana, and Katakana scrips are daily used in a 
   commingled manner based on established orthographies and 
   conventions in Japan. Such comingled use is allowed even in 
   single words. This means Japanese people consider the collective 
   set of Kanji, Hiragana, and Katakana characters to belong to ONE 
   script in constituting Japanese words, just as native English 
   writers/readers consider English characters to belong to ONE 
   script.
 
   Therefore, in the case where comingled use of UNICODE scripts is 
   allowed by Guideline#15, restrictions (if any) should be the same 
   as in the case of one UNICODE script in constituting domain 
   labels.
 
2. In Additional Note IV, the guidelines of visually confusable
   characters are described. We think they are the good notes because
   the issues of visually confusable characters are clearly pointed.
 
   Taking into account the fact that issues of visually confusable 
   characters reside both in the case of a single UNICODE script and 
   in the case where comingled UNICODE scripts are allowed, we think 
   the sentence "must not be allowed to" is overdescribed in 
   guideline#16.
 
[Suggestion]
 
  We would like to propose as follows.
 
  - The guideline#16 is removed from section 2.5.2 and is moved to 
    a newly created section between 2.5.2 and 2.5.3. The new section 
    is headlined as "2.5.X Visually confusable characters".
 
  - The guideline#16 will be modified as follows.
    -------------------------------------------------------------------
    16. 
    Visually confusable characters had better not co-exist in a single
    set of permissible code points. TLD registries should clearly 
    define a corresponding policy and IDN Table to minimize confusion 
    between domain names. Also see Additional Note IV.
 
-------------------------------------------------------------------
 
Thanks for your consideration.
----
Yoshitaka Okuno
Manager, Services Development Department Japan Registry Services Co., 
Ltd.
 
 

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-- 
Kal Feher
@kalfeher