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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In reviewing the proposed String Similarity Evaluation (SSE) data, I appreciate ICANN’s continued commitment to transparency and community engagement. To further strengthen the evaluation framework for the Next Round of gTLDs, I would like to offer several methodological considerations aimed at improving the consistency and predictability of similarity assessments.
Inclusion of semantic and contextual similarity: In addition to visual and phonetic criteria, the evaluation process should take into account cases where strings are semantically related or may create contextual confusion for end-users. This is particularly relevant when applied-for strings resemble well-established geographic names or terms closely associated with national or cultural identity.
Cross-script and transliteration considerations: The evaluation parameters should more fully address the relationship between strings across different scripts, including common transliteration patterns. Although such strings may differ at the code point level, they often represent the same or closely related terms to users, which may warrant inclusion in similarity review to avoid unintended confusion.
Context-aware assessment: In borderline or complex cases, the SSE Panel should have the flexibility to consider contextual information that is publicly available. This would support more accurate determinations of whether two strings, despite minor character differences, could reasonably be perceived as indicating the same geographic origin, affiliation, or authority.
Incorporating these considerations would help ensure that the New gTLD Program is better equipped to identify and mitigate potential conflicts that arise not only from visual similarity, but also from broader linguistic, cultural, and contextual factors relevant to end-user understanding.
Thank you for the opportunity to provide input.