I appreciate the Working Group’s effort to address the identified regulatory gap concerning ASCII and Latin script diacritic gTLDs that are not variants but may be visually confusingly similar. The narrow technical scope, reliance on Unicode decomposition, alignment with the RZ-LGR framework, and the application of the “Same Entity” principle provide a coherent and stability-oriented structure.

To further strengthen the proposal, I would suggest consideration of the following points:

Evidence of Practical Demand

While the policy addresses a structural gap, additional clarity regarding demonstrated or projected demand would reinforce its justification. Data or illustrative cases indicating the scale of need could provide helpful context for evaluating proportionality and long-term impact.

Differentiated Risk Considerations

Although eligibility is based on Unicode decomposition, not all diacritic usages may present equivalent degrees of visual similarity or user confusion. Future implementation guidance or periodic review mechanisms could assess whether differentiated monitoring is warranted based on observed patterns.

Post-Implementation Review

Given the intersection of technical governance and linguistic representation, a structured review (e.g., after 3–5 years) evaluating adoption, security implications, and practical usage would enhance policy resilience. From an academic and research perspective, such data would also contribute to a clearer understanding of how technical inclusion translates into effective multilingual participation online.

Overall, the proposed mechanism appears technically sound and appropriately limited in scope. Strengthening its empirical grounding and incorporating structured monitoring would further enhance its long-term legitimacy and effectiveness.

Thank you for the opportunity to comment.