Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: NITIN WALIA
Date: 13 Feb 2026
Preliminary Recommendation 1
Support Recommendation intent with wording change

Please provide your rationale and/or proposed changes:

The recommendation appropriately defines a clear and limited framework for when an ASCII gTLD and its corresponding Latin diacritic gTLD(s) may qualify as a set. Anchoring eligibility to Unicode decomposition and RZ-LGR conformity provides an objective technical basis and avoids subjective interpretation. The narrow scope is consistent with the Charter and helps ensure predictability and stability. That said, a few clarifications would strengthen the text: 1. Future evolution of Unicode and RZ-LGR : The recommendation references the Unicode Table and RZ-LGR eligibility criteria. It would be useful to explicitly acknowledge that the eligible character set may evolve over time as Unicode and the RZ-LGR are updated. This avoids the impression that the scope is permanently fixed and ensures alignment with established root zone governance processes. 2. Exclusion of non-decomposable Latin letters : The exclusion of characters that cannot be decomposed into ASCII plus combining diacritical marks is understandable within the defined scope of this PDP. However, it would be helpful to clarify in the rationale that this exclusion is purely procedural and does not reflect a linguistic hierarchy or diminish the legitimacy of such characters in other IDN contexts. 3. Requirement for the base ASCII gTLD : The requirement that a base ASCII gTLD must exist for the set to qualify is logical within the framework of this mechanism. It would nonetheless be beneficial to clarify in the rationale whether this requirement is grounded primarily in technical architecture, user confusion mitigation, or policy coherence. This would assist future interpretation. Overall, the intent of the recommendation is sound. With the above clarifications, it would provide a stable and well-defined foundation for the proposed mechanism.

Preliminary Recommendation 2
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The application of the “same entity” principle at the top level is both appropriate and necessary in the context of ASCII/Latin diacritic gTLD sets. Where two strings are visually similar and are intended to function as a coordinated set, allowing different registry operators to control them would introduce a high risk of user confusion, inconsistent policies, and potential abuse. The principle that all gTLDs within the set must be allocated to the same registry operator is therefore a proportionate and practical safeguard. The approach is also consistent with the framework already established under EPDP-IDNs Phase 1. Maintaining alignment with that work is important for policy coherence and avoids creating divergent treatment between variant and non-variant but visually similar strings. From an operational perspective, a single registry operator managing the set enables consistent contractual obligations, harmonized second-level rules, coordinated lifecycle management, and uniform rights protection mechanisms. It also simplifies compliance oversight and reduces complexity for registrars and registrants. In short, the “same entity” requirement is a foundational stability and consumer protection measure. It appropriately balances the objective of enabling linguistic accuracy through diacritics with the need to mitigate confusion and security risk.

Preliminary Recommendation 3
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Requiring a registry operator to submit an application during an established application round in order to obtain the corresponding ASCII or Latin diacritic gTLD(s) is appropriate and consistent with existing New gTLD Program procedures. This approach preserves procedural fairness and ensures that all applications are subject to the same evaluation standards, transparency requirements, and public interest safeguards. It also avoids the creation of an ad hoc or expedited pathway that could undermine predictability or introduce perceptions of preferential treatment. Aligning this mechanism with the established round-based structure of the New gTLD Program maintains coherence with SubPro outputs and EPDP-IDNs Phase 1. It also ensures that string similarity review, objection processes, and other evaluation steps are conducted within a known and tested framework. From an implementation standpoint, routing such applications through formal rounds supports stability and administrative consistency. It provides clarity for applicants, ICANN org, and the community, and avoids operational complexity that could arise from off-cycle processing.

Preliminary Recommendation 4
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Allowing applications for corresponding ASCII or Latin diacritic gTLDs to be submitted during the immediate next application round, as well as in subsequent rounds, is a reasonable and balanced approach. This ensures equal opportunity for existing registry operators while maintaining consistency with the round-based structure of the New gTLD Program. It avoids creating a one-time or limited window that could disadvantage operators depending on timing, readiness, or business planning cycles. The recommendation also appropriately aligns with SubPro outputs regarding the applicability of new policy to future rounds. It provides clarity that the mechanism operates prospectively and does not retroactively alter application procedures already underway. From a planning and operational standpoint, providing access in the immediate next round and future rounds supports predictability and fairness. It gives registry operators sufficient flexibility while preserving program integrity and procedural transparency.

Preliminary Recommendation 5
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately extends the application framework to applicants seeking to apply for an ASCII gTLD string together with its corresponding Latin diacritic gTLD label(s) that constitute a set. Treating such applications within the established application and evaluation framework ensures procedural consistency and avoids creating special treatment outside the defined program structure. It also reinforces the principle that these strings, while related, remain subject to the same transparency, objection, and evaluation safeguards as any other applied-for gTLD. Allowing applicants to submit the ASCII string together with its corresponding Latin diacritic string(s) as a coordinated set reflects the policy intent of enabling simultaneous delegation under controlled conditions. It provides clarity at the outset of the process and reduces uncertainty during evaluation. Overall, the recommendation supports predictability, fairness, and alignment with the broader New gTLD Program architecture.

Preliminary Recommendation 6
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately continues the alignment of the ASCII/Latin diacritic gTLD mechanism with the established evaluation framework of the New gTLD Program. Ensuring that such applications are subject to the standard administrative check and initial evaluation processes maintains fairness, transparency, and predictability. It avoids creating a parallel or modified review track that could introduce inconsistency or unintended procedural advantages. Applying the existing evaluation safeguards is particularly important given the potential for visual similarity and user confusion. The standard string review, technical evaluation, and related checks provide an appropriate layer of scrutiny without requiring additional bespoke mechanisms at this stage. The recommendation is consistent with the overall design of the PDP, which seeks to introduce a narrowly scoped exception while remaining within the established policy and program architecture.

Preliminary Recommendation 7
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures that applications for ASCII/Latin diacritic gTLD sets remain subject to the existing string similarity review and related safeguards within the New gTLD Program. Given that the core issue addressed by this PDP involves strings that may be visually confusingly similar, maintaining the integrity of the established similarity review process is essential. The recommendation avoids carving out exceptions that could weaken consumer protection or create inconsistent treatment across applications. At the same time, the mechanism does not displace the evaluation framework already developed through SubPro and related policy work. This preserves policy coherence and avoids reopening settled issues unnecessarily. Applying standard review processes to these applications ensures that any potential impact on end users, rights holders, or other applicants is properly considered within a structured and transparent framework. It also reinforces the principle that the proposed mechanism is an exception within clearly defined boundaries, not a separate track.

Implementation Guidance 8

Please provide your rationale and/or proposed changes:

Implementation Guidance appropriately provides operational clarity without expanding the policy beyond its intended scope. The guidance supports consistent application of the evaluation framework while allowing ICANN org sufficient flexibility to operationalize the recommendations within the Applicant Guidebook and related implementation materials. This balance is important. Over-specifying implementation details at the policy level could unnecessarily constrain execution or create rigidity in future rounds. The guidance also reinforces procedural predictability. Applicants benefit from clear expectations, and evaluators benefit from structured direction, while remaining within the established program architecture. Importantly, the guidance does not introduce new substantive policy obligations. Instead, it helps ensure that the mechanism defined in the preliminary recommendations can be implemented in a coherent and administratively workable manner.

Preliminary Recommendation 9
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures that applications involving ASCII/Latin diacritic gTLD sets are handled within the established procedural and evaluative safeguards of the New gTLD Program. The recommendation maintains consistency with prior policy work and avoids creating a separate or preferential pathway. This is important to preserve fairness among applicants and to ensure that visually similar strings are assessed through existing mechanisms designed to evaluate string contention, similarity, and potential user confusion. By embedding these applications within the standard framework, the recommendation supports predictability for applicants, evaluators, and the broader community. It also reinforces the principle that the proposed mechanism is a narrowly tailored exception, not a broader structural shift in the program. The approach is proportionate, administratively workable, and aligned with established policy architecture.

Implementation Guidance 10
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Implementation Guidance appropriately clarifies how the related preliminary recommendation should be operationalized within the existing New gTLD Program framework. The guidance supports consistency in evaluation and administrative processing while allowing ICANN org the necessary flexibility to reflect the policy outcome in the Applicant Guidebook and associated procedures. It does not introduce new substantive requirements, but rather helps ensure that the policy intent is implemented in a predictable and structured manner. Maintaining implementation detail at the guidance level — rather than embedding it rigidly in policy language — is appropriate. It provides room to address operational realities without reopening the policy framework in future rounds. The guidance is proportionate, aligned with existing processes, and sufficient to support practical execution.

Implementation Guidance 11
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Implementation Guidance provides appropriate operational direction to support the corresponding recommendation without expanding the policy beyond its intended scope. The guidance reinforces predictability in how applications involving ASCII/Latin diacritic gTLD sets should be handled during evaluation and implementation. It supports consistency with the established New gTLD Program processes while allowing ICANN org reasonable flexibility in translating policy into operational detail. From a broader perspective, clear implementation guidance is particularly important in cases involving visually similar strings. Transparent and consistent handling reduces uncertainty for applicants and enhances user trust once such strings are delegated. This, in turn, supports responsible adoption of IDNs, including those that more accurately reflect linguistic usage. The guidance strikes an appropriate balance between clarity and flexibility.

Preliminary Recommendation 12
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately continues the effort to integrate ASCII/Latin diacritic gTLD sets into the established New gTLD Program framework without creating a parallel or exceptional track. By aligning the treatment of these strings with existing evaluation and procedural safeguards, the recommendation preserves fairness across applicants and ensures that any potential risk of confusion is addressed within a structured and transparent system. This consistency is important for maintaining trust in the program. At the same time, the recommendation supports the orderly introduction of gTLDs that reflect accurate linguistic forms. Providing a clear and predictable pathway for such strings encourages responsible uptake while safeguarding stability and user protection. The approach is proportionate, administratively workable, and consistent with prior policy work.

Preliminary Recommendation 13
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation continues the structured integration of ASCII/Latin diacritic gTLD sets into the existing program framework and appropriately reinforces consistency in evaluation and delegation procedures. Maintaining alignment with established New gTLD Program safeguards is important to avoid unintended gaps or inconsistencies, particularly in cases involving visually similar strings. The recommendation supports predictability for applicants, clarity for evaluators, and coherence with previously adopted IDN-related policy. At the same time, by enabling clearly defined pathways for corresponding ASCII and Latin diacritic strings, the recommendation supports accurate linguistic representation in the DNS while operating within well-understood safeguards. This balance between enablement and stability is appropriate. The recommendation is proportionate, consistent with prior work, and operationally sound.

Preliminary Recommendation 14
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately continues the consistent treatment of ASCII/Latin diacritic gTLD sets within the broader New gTLD Program framework. The recommendation reinforces that these strings should be subject to the same structured safeguards and contractual expectations as other gTLDs. This approach maintains fairness, avoids fragmentation of policy treatment, and supports program integrity. Given the visual similarity considerations inherent in this PDP, maintaining consistency in obligations and oversight is particularly important. It reduces the potential for divergent operational practices that could increase user confusion or undermine trust. At the same time, providing a clear and predictable framework for coordinated ASCII and Latin diacritic strings supports responsible expansion of linguistically accurate domain names. The balance struck in this recommendation between stability, transparency, and enablement is appropriate

Preliminary Recommendation 15
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately addresses the contractual alignment required for ASCII/Latin diacritic gTLD sets. Where strings are intended to operate as a coordinated set under the same registry operator, contractual consistency is essential. Clear and harmonized Registry Agreement provisions reduce ambiguity in enforcement, compliance, and operational oversight. This is particularly important in cases involving visually similar strings, where divergent contractual obligations could create confusion or uneven treatment. The recommendation maintains coherence with the broader contractual framework already established in the New gTLD Program. It avoids creating a special contractual regime while ensuring that the relationship between the strings in the set is reflected in binding obligations. From a stability and user trust perspective, aligned contractual terms support predictable operation and accountability. At the same time, they provide registry operators with clarity regarding their responsibilities when managing coordinated ASCII and Latin diacritic strings. In short the recommendation is proportionate and operationally sound.

Implementation Guidance 16
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Implementation Guidance appropriately complements the corresponding contractual recommendation by clarifying how the obligations should be reflected in practice. Ensuring that ASCII and Latin diacritic gTLDs within a set are treated consistently at the contractual level is important for operational clarity and compliance oversight. The guidance supports coherent implementation without introducing additional substantive policy requirements. By allowing ICANN org to reflect the policy outcome through appropriate Registry Agreement provisions and related documentation, the guidance maintains necessary flexibility while preserving the intent of the recommendation. This balance is important to avoid over-specification at the policy level. Clear contractual alignment also contributes to user trust and predictable operation of coordinated strings, which is particularly relevant when introducing linguistically accurate diacritic forms that may be visually similar to existing ASCII labels. The guidance is proportionate and workable

Preliminary Recommendation 17
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately continues the contractual coherence framework for ASCII/Latin diacritic gTLD sets. When strings are approved to operate as a coordinated set, the underlying contractual structure must clearly reflect that relationship. Consistency in rights, obligations, and compliance expectations is necessary to prevent fragmentation in how the strings are administered and overseen. The recommendation reinforces predictability for registry operators and clarity for ICANN org in monitoring compliance. It also reduces the likelihood of divergent practices that could undermine user confidence, particularly in cases involving visually similar strings. At the same time, the approach does not introduce new or disproportionate obligations. It simply ensures that the policy intent coordinated operation under defined safeguards is properly embedded in enforceable agreements. The recommendation is balanced, aligned with the broader New gTLD Program architecture, and operationally sound.

Preliminary Recommendation 18
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures continued contractual and operational consistency within an ASCII/Latin diacritic gTLD set. Maintaining aligned obligations and oversight across the set supports stability and reduces the risk of divergent practices that could affect user trust. The recommendation remains proportionate and consistent with the broader Registry Agreement framework, while enabling coordinated operation of linguistically accurate strings.

Preliminary Recommendation 19
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately reinforces coherent contractual treatment within an ASCII/Latin diacritic gTLD set. Clear alignment of obligations across the set supports consistent operation, compliance, and user expectations. The approach remains proportionate and does not introduce unnecessary complexity, while enabling accurate linguistic representation under structured safeguards.

Preliminary Recommendation 20
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately provides operational clarity while maintaining consistency with established registry practices. Clear treatment of status codes and lifecycle handling within an ASCII/Latin diacritic gTLD set supports predictable operation and reduces the risk of inconsistent domain management. The recommendation aligns with existing technical standards and reinforces coordinated administration of related strings.

Preliminary Recommendation 21
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately maintains consistency in how ASCII and Latin diacritic gTLDs within a set are administered. Ensuring coordinated treatment across the set supports stability, predictability, and user trust. The recommendation aligns with existing operational and contractual frameworks without introducing unnecessary complexity.

Preliminary Recommendation 22
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately preserves alignment in the treatment of ASCII and Latin diacritic gTLDs within a coordinated set. Consistent handling across the set strengthens operational clarity and supports user confidence, particularly where strings may appear visually similar. The recommendation remains proportionate and consistent with the broader contractual and policy framework.

Preliminary Recommendation 23
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately continues the structured alignment of obligations within an ASCII/Latin diacritic gTLD set. Maintaining coordinated operational and compliance treatment across the set supports stability and minimizes the risk of inconsistent practices. The recommendation fits within the established Registry Agreement framework and enables responsible introduction of linguistically accurate strings.

Preliminary Recommendation 24
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures that continuity mechanisms, including EBERO-related considerations, are applied consistently across an ASCII/Latin diacritic gTLD set. Extending continuity safeguards to all strings within the set supports operational resilience and protects registrants in the event of registry failure. Given the coordinated nature of these strings, aligned treatment is both logical and necessary. The recommendation strengthens stability without adding undue complexity.

Preliminary Recommendation 25
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures that rights protection mechanisms are applied consistently across all strings within an ASCII/Latin diacritic gTLD set. Given the potential for visual similarity, aligned treatment under RPMs is important to safeguard rights holders and maintain user confidence. The recommendation reinforces fairness and predictability without creating additional procedural complexity.

Preliminary Recommendation 26
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately maintains consistent policy and contractual treatment across the ASCII and Latin diacritic strings within a set. Ensuring uniform application of obligations and safeguards supports stability and reduces the likelihood of inconsistent enforcement or user confusion. The approach remains proportionate and aligned with the broader New gTLD Program framework.

Implementation Guidance 27
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Implementation Guidance appropriately supports the corresponding recommendation by clarifying how aligned obligations should be reflected in practice. Providing operational direction at the guidance level allows ICANN org to implement the policy coherently while retaining necessary flexibility. It reinforces consistent treatment across the ASCII/Latin diacritic gTLD set and supports predictable administration.

Preliminary Recommendation 28
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately ensures that any applicable safeguards, including Category 1 requirements, apply consistently across all strings within an ASCII/Latin diacritic gTLD set. Applying identical restrictions to each string in the set prevents regulatory or compliance gaps and maintains a level playing field. It also reduces the risk of user confusion that could arise if one string were subject to stricter safeguards than its corresponding string. The recommendation preserves policy coherence and supports responsible operation of linguistically accurate strings.

Preliminary Recommendation 29
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately addresses delegation conditions in a manner that prioritizes stability and coordinated operation within an ASCII/Latin diacritic gTLD set. Clear rules around delegation help prevent fragmented activation and reduce the risk of inconsistent treatment that could affect user trust. The recommendation maintains a conservative and stability-focused approach while still enabling accurate linguistic representation where appropriate.

Preliminary Recommendation 30
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately clarifies the conditions under which coordinated strings within an ASCII/Latin diacritic gTLD set may be delegated or managed. Maintaining structured and predictable delegation rules supports DNS stability and avoids operational ambiguity. At the same time, the recommendation preserves the intended flexibility to enable accurate linguistic forms within defined safeguards.

Preliminary Recommendation 31
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately addresses removal scenarios in a structured and predictable manner. Clear rules governing the relationship between ASCII and Latin diacritic strings at the point of removal are essential to preserve stability and avoid inconsistent states within the set. The recommendation reinforces coordinated lifecycle management while minimizing potential user confusion.

Preliminary Recommendation 32
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Clear rules governing allocation status and coordination across the set are important to prevent conflicting registrations and reduce the risk of user confusion. The recommendation aligns with established IDN variant management principles while adapting them to the defined scope of this PDP.

Preliminary Recommendation 33
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Ensuring consistent allocation and lifecycle handling across related strings reduces the likelihood of conflicting registrations and supports user confidence. The recommendation reflects established variant management principles while remaining within the defined scope of this PDP.

Implementation Guidance 34
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Providing guidance at this level supports consistent application across ASCII and Latin diacritic strings while preserving flexibility for implementation. It reinforces coordinated lifecycle management and helps avoid inconsistencies that could affect registrants or end users.

Preliminary Recommendation 35
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Defining how the set is affected in such circumstances is important to preserve policy clarity and avoid ambiguity in root zone management. The approach maintains structural consistency while minimizing the risk of unstable or partially defined states.

Preliminary Recommendation 36
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Providing structured and predictable rules for such cases supports root zone stability and avoids ambiguity in how coordinated strings are managed. The recommendation maintains consistency with the overall framework governing ASCII/Latin diacritic gTLD sets.

Implementation Guidance 37
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

Clear operational direction helps ensure that removal scenarios are handled consistently and without unintended disruption to registrants or users. The guidance reinforces stability while allowing implementation flexibility where needed.

Preliminary Recommendation 38
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Clear and predictable handling reduces operational uncertainty and supports user trust. The recommendation aligns with the broader framework established throughout the PDP and remains proportionate.

Preliminary Recommendation 39
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Providing a precise definition at this stage is essential for predictable allocation, lifecycle management, and enforcement of the same-entity principle. It reduces ambiguity and prevents inconsistent second-level handling across related strings. A well-defined second-level framework is particularly important to support stable and responsible use of linguistically accurate domain names.

Preliminary Recommendation 40
Support Recommendation as written

Please provide your rationale and/or proposed changes:

Preliminary Recommendation appropriately extends the “same entity” principle to the second level. Requiring coordinated allocation across the ASCII/Latin diacritic domain set minimizes the risk of conflicting registrations and reduces potential user confusion. It aligns with established IDN variant management principles while adapting them to this specific framework. The recommendation strengthens consistency and predictability at the second level.

Implementation Guidance 41
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

The guidance appropriately clarifies how second-level coordination and harmonization should be operationalized in practice. Clear alignment of IDN Tables across the set is essential to prevent inconsistent variant generation and conflicting allocation outcomes. Providing implementation direction at this level supports technical predictability while allowing sufficient flexibility for registry operators to manage updates responsibly. The approach reinforces stability and coherent second-level management.

Preliminary Recommendation 42
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately strengthens second-level coordination within the ASCII/Latin diacritic framework. Ensuring consistent allocation rules across the set helps prevent fragmentation and reduces the risk of inconsistent treatment of related domain names. This supports stability and predictable user experience, while enabling accurate linguistic forms under structured safeguards.

Preliminary Recommendation 43
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately reinforces harmonized second-level management across coordinated strings. Maintaining consistent rules and treatment within the set reduces operational ambiguity and supports user confidence, particularly where visually similar forms are involved. The approach aligns with established IDN principles and remains proportionate.

Preliminary Recommendation 44
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately addresses IDN Table harmonization across the coordinated set. Ensuring that second-level rules generate consistent outcomes across related strings is essential to prevent conflicting allocations and preserve predictability. Clear harmonization requirements strengthen stability while supporting accurate linguistic representation within defined safeguards.

Preliminary Recommendation 45
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately clarifies responsibilities related to identifying and managing the source domain name within the coordinated set. Clear delineation of roles between registrant and sponsoring registrar supports orderly lifecycle management and reduces the risk of inconsistent handling. This strengthens predictability at the second level while preserving operational practicality.

Preliminary Recommendation 46
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately ensures coordinated lifecycle treatment across the ASCII/Latin diacritic domain set. Aligning activation, expiration, and related status handling reduces the likelihood of inconsistent states and supports user clarity. Clear lifecycle rules are particularly important where visually similar domain names are involved.

Preliminary Recommendation 47
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately maintains coordinated handling of lifecycle events within the ASCII/Latin diacritic domain set. Consistent treatment during transfers, renewals, or other status changes reduces the risk of fragmentation and protects registrants from unintended outcomes. Clear and predictable lifecycle rules support both operational stability and user confidence.

Preliminary Recommendation 48
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately ensures that existing rights protection mechanisms apply consistently across the coordinated set. Uniform treatment under established dispute resolution processes strengthens predictability for rights holders and registrants alike. It also avoids creating gaps that could arise if visually similar strings were subject to differing RPM treatment. The approach is aligned with existing policy

Implementation Guidance 49
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

The guidance appropriately clarifies how rights protection mechanisms should be applied in practice across the coordinated set. Providing implementation direction supports consistent enforcement while maintaining alignment with existing RPM frameworks. It reinforces predictability for registrants and rights holders without introducing new substantive obligations. The guidance is proportionate

Preliminary Recommendation 50
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately reinforces consistent lifecycle and allocation handling across the coordinated domain set. Clear and uniform treatment reduces ambiguity for registrants and registrars and helps prevent unintended divergence between visually related domain names. The approach aligns with established IDN management principles and supports predictable operation.

Preliminary Recommendation 51
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately maintains consistent handling of allocation and lifecycle events within the coordinated set. Ensuring that related domain names remain subject to aligned rules reduces operational complexity and minimizes the risk of inconsistent states. This supports stability and helps maintain user confidence where visually similar forms are involved.

Implementation Guidance 52
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

The guidance appropriately clarifies how coordinated lifecycle and allocation rules should be implemented in practice. Providing structured implementation direction supports consistent treatment across the ASCII/Latin diacritic domain set while preserving operational flexibility. It reinforces predictability for registrars and registrants and helps avoid unintended divergence between related domain names.

Preliminary Recommendation 53
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The recommendation appropriately reinforces coordinated treatment of related domain names within the set. Maintaining consistent rules across allocation, activation, and lifecycle events reduces the potential for fragmentation and supports a predictable user experience. The approach aligns with established IDN management principles and remains proportionate.

Implementation Guidance 54
Support Implementation Guidance as written

Please provide your rationale and/or proposed changes:

The guidance appropriately supports coherent execution of the lifecycle and coordination rules established throughout this section. Clear implementation direction helps ensure that registry operators and registrars apply the framework consistently, particularly where related domain names must be managed in a synchronized manner. This strengthens operational predictability and user confidence while remaining within the established policy structure. The guidance is practical and proportionate.

LD PDP WG’s Response to Charter Question 2: ccTLD Fast Track Process

No additional transferable issues have been identified beyond those already considered by the Working Group. The ccTLD Fast Track Process was designed within a different policy and operational context, particularly in relation to country code strings and sovereign considerations. The LD PDP appropriately assessed its relevance and concluded that its structural elements are not directly transferable to the ASCII/Latin diacritic gTLD mechanism.

The current framework for coordinated ASCII/Latin diacritic gTLD sets relies on the same-entity principle, harmonized second-level management, and round-based application procedures. These elements are better aligned with the generic TLD environment and established New gTLD Program architecture. As such, no further aspects of the ccTLD Fast Track Process appear necessary or suitable for incorporation into this PDP.

LD PDP WG’s Response to Charter Question 4: ICANN’s Existing Consensus Policies

Yes, the impact analysis is generally sound and proportionate. The Working Group has correctly identified that the proposed mechanism does not introduce fundamental changes to ICANN’s existing Consensus Policies. Rather, it extends established principles particularly around coordinated management, rights protection mechanisms, and lifecycle handling into a narrowly defined ASCII/Latin diacritic context. The analysis appropriately recognizes that existing frameworks such as the UDRP, URS, transfer policies, and other contractual obligations can apply consistently across the coordinated set without requiring structural amendments. This preserves policy coherence and avoids unnecessary reopening of settled policy work. At the same time, it will be important during implementation to ensure that no unintended operational conflicts arise at the second level, particularly in areas involving synchronized lifecycle management. This is an implementation consideration rather than a policy gap. Overall, the impact analysis is reasonable and aligned with the limited scope of the PDP.

Do you agree with the LD PDP WG’s impact analysis on Global Public Interest (GPI)? If not, please provide details below.

The analysis is generally appropriate and well aligned with the scope of the PDP. The mechanism seeks to enable more accurate linguistic representation while maintaining stability safeguards. In that sense, it advances the Global Public Interest by supporting inclusivity and predictability in the DNS without introducing disproportionate risk. The recognition that user trust, security, and stability remain central considerations is important. At the same time, facilitating the responsible use of diacritic forms can reduce incentives to omit native orthography and supports broader participation in the domain name system. Overall, the GPI assessment is balanced and consistent with the limited and technical nature of this policy development effort.

Do you agree with the LD PDP WG’s impact analysis on Human Rights (HR)? If not, please provide details below.

The analysis is generally sound and proportionate to the scope of this PDP. The proposed mechanism neither restricts expression nor introduces differential access based on language. On the contrary, by enabling coordinated operation of ASCII and Latin diacritic strings under defined safeguards, it supports the ability of users and communities to reflect accurate linguistic forms in domain names. The Working Group appropriately notes that the policy remains technical and operational in nature. At the same time, facilitating consistent treatment of diacritic forms can indirectly support cultural and linguistic expression within the DNS, provided stability and user protection remain intact. Overall, the Human Rights assessment is balanced and consistent with the limited but meaningful scope of this policy effort.

Are there any issues pertaining to Latin script diacritics gTLDs that the LD PDP WG has not considered? If yes, please provide details below.

The report is comprehensive and addresses the principal structural and operational issues associated with ASCII and Latin diacritic gTLD sets. One area that may warrant additional attention during implementation is user awareness and system readiness. While the policy framework is stability-focused, successful deployment will also depend on consistent support across applications, browsers, and email systems. Clear communication and coordination during implementation could help reduce user confusion and encourage proper use of diacritic forms rather than fallback to ASCII-only variants. Additionally, periodic review after implementation could be considered to assess whether the mechanism is functioning as intended, particularly with respect to second-level coordination and user behavior patterns. This would allow adjustments if practical challenges emerge. Beyond these implementation-oriented considerations, no major unaddressed policy issues have been identified.

Are there any comments or issues you would like to raise pertaining to Section 3. Glossary (pages 10-25) of the Initial Report? If yes, please provide your comments here.

The glossary is generally clear and well structured. It provides useful definitions that support consistent interpretation throughout the report.

One minor suggestion is to ensure that closely related terms such as “ASCII/Latin diacritic gTLD set,” “ASCII/Latin diacritic domain set,” “source domain name,” and “corresponding domain name” are cross-referenced where appropriate. This would help readers quickly understand how the top-level and second-level concepts relate to one another. It may also be helpful to confirm consistent usage of terms such as “visually similar,” “variant,” and “non-variant” to avoid any unintended ambiguity with existing EPDP-IDNs terminology.

Are there any comments or issues you would like to raise pertaining to Annex C – Stress Test: Edge Cases (pages 113-121) of the Initial Report? If yes, please provide your comments here.

Annex C is thorough and appropriately stress-tests the framework against realistic edge cases, particularly around delegation sequencing, removal scenarios, and second-level coordination. One point that may merit additional reflection is user behavior in environments where diacritics are inconsistently supported or easily omitted in input methods. While this is not a policy defect, it may influence how coordinated strings are perceived and used in practice. A brief acknowledgement of usability and ecosystem readiness considerations could strengthen the analysis. It may also be useful to consider how the mechanism would operate in situations involving registry transfers or corporate restructuring, to ensure continuity of the “same entity” principle in less typical ownership scenarios. Overall, the stress testing appears robust and consistent with the stability-focused intent of the PDP.

Other Comments

Overall, the report reflects a careful and measured approach to a narrowly scoped policy issue. The framework appropriately balances stability, predictability, and linguistic accuracy. One broader observation relates to implementation planning. Given that the mechanism introduces coordinated operation of visually similar strings, clear communication in the Applicant Guidebook and related implementation materials will be important to avoid misinterpretation by applicants and registrars. Early clarity on procedural expectations could help ensure smooth execution in future rounds. It may also be helpful to consider, at an appropriate stage, whether a post-implementation review specific to this mechanism would be beneficial. This would allow the community to assess whether the safeguards and coordination rules are functioning as intended, particularly at the second level. Beyond these general observations, the report is coherent, internally consistent, and aligned with existing IDN-related policy work.