Submitted by PT Aidi Digital Global ("PT ADG"), an ICANN-evaluated Registry Service Provider (RSP) headquartered in Indonesia (https://www.adg.id). These comments are provided by the undersigned Director on behalf of PT ADG.

1. Overall position

PT ADG supports the publication of all eight Reference LGRs in this proceeding: the two new Reference LGRs (Javanese script and Unified Canadian Aboriginal Syllabics), and the six updated Reference LGRs (Arabic script, Inuktitut language, Japanese language, Japanese script, Latin script, and Latin script Full Variant). We commend ICANN org and the relevant language and script communities for continuing to expand the Second-Level Reference LGR framework in a transparent, consultative, and security-conscious manner.

2. Relevance to Indonesia and our market

Two of the updates are of direct significance to the communities PT ADG serves. The new Javanese script (Aksara Jawa) Reference LGR brings one of Indonesia's major living writing systems into the standardized, machine-readable LGR framework. The addition of two characters to the Arabic script Reference LGR to support the Pegon writing system likewise recognizes a script used for centuries to write Javanese, Sundanese, Madurese, and other local languages in Arabic-derived characters. As an Indonesian RSP, we see clear demand and cultural value in enabling these scripts at the second level, and we support their inclusion.

This proceeding also builds on an established Indonesian precedent: the Balinese script (Aksara Bali) Second-Level Reference LGR published by ICANN in 2024, developed by the Indonesian community (PANDI in collaboration with Universitas Udayana) and recognized as the first second-level IDN initiative in Indonesia. The addition of Javanese and Pegon is a natural and welcome continuation of that work, and demonstrates that the community-driven Reference LGR model is delivering tangible results for Indonesian scripts.

3. Registry Service Provider (operational) perspective

The principal value of Reference LGRs from an RSP standpoint is consistency and predictability. We therefore highlight the following:

a) Review efficiency. Because these Reference LGRs are community-developed and published in machine-readable form, they provide an authoritative baseline against which gTLD registry IDN tables can be checked. This reduces ambiguity in the IDN table review process, shortens review cycles, and lowers the operational and compliance burden on RSPs that onboard registries wishing to offer these scripts.

b) Alignment with RZ-LGR-6. We specifically welcome the additional rules added to the Japanese language and Japanese script Reference LGRs to ensure that iteration marks and the prolonged sound mark are not repeated and do not follow U+3006, aligning these with the Root Zone LGR version 6. Maintaining a single, coherent rule set across the root and second levels avoids divergence that would otherwise create implementation and validation inconsistencies for service providers operating at both levels.

c) Variant handling. The added cross-script variants for Inuktitut (arising from the new UCAS Reference LGR) and for the Latin script Full Variant (the cross-script variant between U+028C and U+03BB arising from the newly added U+028C) are important for blocking confusable allocations. We support a conservative, variant-aware approach, as it directly serves the security and stability objectives that underpin the Reference LGR program.

4. Security, stability, and confusability

We support the program's emphasis on managing homograph and confusability risk. Newly added scripts such as Javanese contain characters that can be visually similar to one another and to characters in other scripts; the careful definition of variants, context rules, and whole-label rules in these Reference LGRs is essential to mitigating spoofing risk. We encourage ICANN org to continue treating cross-script confusability as a first-order requirement as additional scripts are added.

5. Universal Acceptance

Reference LGRs are a necessary foundation, but they deliver end-user value only when domains in these scripts are universally accepted. As a service provider, PT ADG regards Universal Acceptance readiness as an important objective and supports the broader UA effort. We encourage ICANN org to pair the publication of these Reference LGRs with continued Universal Acceptance guidance, test data, and outreach to application and platform developers, so that labels validly generated under these LGRs actually resolve, display, and are accepted across email and web applications. Without parallel UA progress, the cultural and economic benefits of these additions will be limited.

6. Accuracy of the published rule sets

We note that contributors to the Javanese script proposal have identified at least one drafting matter in the supporting documentation regarding the relationship between the relevant rules in Section 7.4 (the characters that may follow the Javanese vowel signs). We support ICANN org and the community working group resolving any such textual or rule-level corrections prior to finalization, so that the published HTML and XML LGRs are internally consistent and unambiguous for implementers.

7. Recommendations

PT ADG respectfully recommends that ICANN org:

- Finalize and publish the Reference LGRs promptly after this proceeding, so RSPs and registries can begin implementation planning;

- Ensure the published HTML and XML artifacts are consistent with each other and reflect any community-identified corrections;

- Continue to couple Reference LGR publication with Universal Acceptance enablement (tooling, test cases, and developer outreach); and

- Maintain the consultative, community-driven model and, building on the Balinese (Aksara Bali) Reference LGR already published in 2024, extend it to additional Indonesian scripts of significant community interest, such as Sundanese, in future proceedings.

8. Conclusion

PT ADG endorses the adoption of the proposed new and updated Second-Level Reference LGRs and stands ready to support their implementation and the adoption of Javanese, Pegon, and other scripts in the Indonesian market. We thank ICANN org and the language and script communities for their continued work.

Respectfully submitted,

Director, PT Aidi Digital Global (PT ADG)

[email protected] | https://www.adg.id

Aidi Digital Global (ADG), an ICANN-evaluated Registry Service Provider based in Indonesia, strongly supports the publication of all eight new and updated Second-Level Reference LGRs in this proceeding.

We particularly welcome the two additions most relevant to Indonesia: the new Javanese script Reference LGR, and the two Arabic-script characters added to support the Pegon writing system. Together with the new UCAS Reference LGR and the updates to Inuktitut, Japanese, and Latin, these advance ICANN's commitment to a multilingual, secure, and inclusive Domain Name System.

From a Registry Service Provider perspective, we value that these Reference LGRs are community-developed, machine-readable, and aligned with RZ-LGR-6. This consistency directly improves the predictability and efficiency of the IDN table review process and lowers the operational burden on registries that wish to offer IDNs in these scripts.

We recommend that ICANN org: (1) publish the finalized Reference LGRs promptly so registries can begin implementation; (2) pair publication with Universal Acceptance guidance and tooling so that domains in these scripts resolve and are accepted consistently across applications; and (3) maintain its consultative, community-driven model. The Balinese script (Aksara Bali) Reference LGR published in 2024, developed by the Indonesian community (PANDI with Universitas Udayana), is a strong precedent, and we encourage extending the same model to further Indonesian scripts such as Sundanese.

As an Indonesia-based RSP, ADG is committed to supporting the implementation and adoption of these scripts in our market. We thank ICANN org and the relevant language and script communities for this work and encourage adoption of the proposed Reference LGRs.