Any allocatable variant label of an existing (delete 'IDN') gTLD (delete 'from the 2012 round'), as calculated by the RZ-LGR, can only be allocated to the same registry operator (delete 'of the existing IDN gTLD') or withheld for possible allocation only to that registry operator.

A future IDN gTLD applicant must be required, as part of the application process, to explain why it seeks one or more allocatable variant label(s) of its applied-for primary IDN gTLD string. The same requirement applies to existing registry operators (delete 'from the 2012 round') who wish to apply for allocatable variant label(s) of their existing IDN gTLDs

A future IDN gTLD applicant must be required to demonstrate its ability to manage the applied-for primary IDN gTLD string and applied-for allocatable variant label(s) from both a technical and operational perspective. The same requirement applies to existing registry operators (delete 'from the 2012 round') who wish to apply for allocatable variant label(s) of their existing IDN gTLDs.

ICANN org may conduct research that helps identify widely acceptable practices (delete 'standards or tests') that may (delete 'should') be used to evaluate the technical and operational capability to manage a (delete 'the') variant label set at the registry level.

The scope and scale at which the IDN EPDP will enable variant domain names is unprecedented (i.e. variants at the top-level). There is limited experience in this space, with the notable example of NGO/ONG technical bundle. While conducting research to identify acceptable practices is a good idea, we believe it is premature to think that "standards" can be identified at an early stage.

The fee structure associated with future IDN gTLD applications that include variant label(s), as well as applications for variant label(s) of existing IDN gTLDs from existing registry operators (delete 'from the 2012 round'), must be consistent with the principle of cost recovery reflected in the 2012 Applicant Guidebook and affirmed by the New gTLD Subsequent Procedures PDP.53

Understanding the intent of this recommendation is to ensure the integrity of the variant set and treat all variant labels of a primary IDN gTLD the same, we suggest amending to read  “Any future IDN gTLD along with its variant labels (if any) must be subject to one Registry Agreement with substantially similar SLAs and other operational requirements for each variant label.”

In order to encourage a positive and predictable registrant experience, a framework for developing non-binding guidelines for the management of gTLDs and their variant labels at the top-level by registries and registrars must be created during implementation.

The framework should outline the scope and the steps involved in developing future non-binding guidelines, which at a minimum should involve relevant stakeholders, such as registries, registrars, and where feasible, registrants who have experience with IDNs and variant labels.

For clarity and consistency, we suggest a global change to the usage of the phrase “IDN gTLD registry operators of the 2012 round” to simply gTLDs to ensure there is no confusion that this is applicable to all existing gTLDs and not only those established out of the 2012 application round. This global change would apply everywhere except for recommendations 3.14 and 3.15 where it would change the intent of the recommendation.

This is especially important to ensure clarity where the recommendations establish rights of existing registry operators of existing gTLDs the rights to the associated IDN variants. Even if the existing operator does not apply, those rights remain. 

The Registries Stakeholder Group (RySG) provided feedback on selected recommendations of the Phase 1 Initial Report on the Internationalized Domain Names EPDP.