Dear All, We had a short discussion on the number of allocatable variants and whether these could be reduced - as an item to discuss by this study group. During the discussion, the SSAC recommendation was referred, and it was suggested to have IP input in the process. These are shared below for your reference. Regards, Sarmad SSAC ==== Security and Stability Advisory Committee (SSAC) in Recommendation 14 of [SAC060<https://www.icann.org/en/system/files/files/sac-060-en.pdf>], states: Variants introduce a permutation issue both at the top level as well as with combinations of top level and second level: * At the TLD level, assume a TLD string with four characters, where each character has three variants. Thus the variant set created would be 3^4= 81 different strings. The size of the variant sets can grow exponentially. * At 2LD level, assume a 2LD string with four characters, where each character has three variants, and the same number for top level. Thus the variant set created would be 3^4 x 3^4= 72171. SSAC goes on to explain that the numerosity of domain names may result in problems: Such large number of variant strings presents challenges for the management of variant domains at the registry, the registrar and registrant levels. We have seen that some registries have imposed additional rules for variants ... Conservatism is also to be used in this case for the root as well. SSAC concludes that "ICANN should ensure that the number of strings that are activated is as small as possible." This can be ensured by minimizing both the TLD and 2LD variant labels and their combinations. Integration Panel ============== Integration states as part of the release of RZ-LGR-1<https://www.icann.org/sites/default/files/lgr/lgr-1-overview-24feb16-en.pdf> state the following (LGR = RZ-LGR): There are limitations to what can be done with mechanical application of rules, and in some cases, it is not possible to reduce the number of allocatable labels that is practicable and safe without creating undue restrictions on otherwise valid labels. In this context it is a useful reminder that having a label that is "allocatable" neither means that it will necessarily be delegated, nor that it necessarily should be delegated. In fact, investigations of actual registrations on the second level reveal that applicants have tended to apply for only a small number of variant labels. The LGR can be thought of as creating a maximal set of valid labels and allocatable variants, but other steps in the registration process are expected to include suitable mechanisms to shortlist the set of labels for delegation. It is the view of the Integration Panel that such shortlisting is absolutely necessary, because increasing numerocity of delegated variant is concomitant with an increased risk to the DNS.