Dear Yoshitaka Okuno, Thank you for your email. Kindly note that some members of the WG are currently attending the GDD summit in Vancouver, so there may be some delay in further response. We will get back to you soon. Regards, Sarmad -----Original Message----- From: yoshitaka@jprs.co.jp [mailto:yoshitaka@jprs.co.jp] Sent: Friday, May 11, 2018 2:49 PM 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.

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Thanks for your consideration. ---- Yoshitaka Okuno Manager, Services Development Department Japan Registry Services Co., Ltd.