This attachment is submitted in addition to the information provided in the online Public Comment Proceeding form. It contains my full individual Public Comment on the “Second-Level Reference Label Generation Rules — LGRs,” including a structured introduction, general position, and detailed observations organized by topic.

In the attachment, I explain my overall support for the publication of the new and updated Second-Level Reference LGRs, subject to any specific technical concerns raised by the relevant language and script experts. I highlight the significance of the newly added Javanese and Unified Canadian Aboriginal Syllabics (UCAS) Reference LGRs, as well as the proposed updates to the Arabic, Inuktitut, Japanese, Latin, and Latin Full Variant Reference LGRs. I emphasize linguistic inclusion, end‑user trust and security, the treatment of variants and cross‑script variants, and the need for accessible explanatory materials for non‑technical stakeholders.

The attachment should therefore be read as a more complete and nuanced explanation of the key points summarized in the form, including concrete recommendations on documentation, community consultation, and the communication of variant and security implications.

This submission is made in my individual capacity and expresses overall support for the publication of the new and updated Second-Level Reference Label Generation Rules — LGRs, subject to any specific technical concerns identified by language and script experts. I welcome the addition of new Reference LGRs for the Javanese and Unified Canadian Aboriginal Syllabics (UCAS) scripts, and I support the proposed updates to existing Reference LGRs for Arabic, Inuktitut, Japanese, Latin, and the Latin Full Variant set.

At a high level, my submission underscores three main points. First, the expansion and refinement of Second-Level Reference LGRs are important steps toward a more multilingual, inclusive, and user‑centered DNS, particularly for communities whose scripts and languages have historically been underrepresented. Second, I stress that IDN expansion must be accompanied by strong safeguards for end‑user trust, security, and predictability, including careful treatment of variant labels, cross‑script variants, and user‑confusion risks. Third, I recommend that ICANN org provide clear, accessible explanatory materials alongside the technical HTML/XML files so that non‑technical stakeholders, including language communities and civil society, can better understand the impact of these Reference LGRs.

Overall, I support the publication of these new and updated Second-Level Reference LGRs and encourage ICANN org to continue grounding its work in community consultation, transparent documentation, and alignment with Root Zone LGR principles where appropriate.