Please provide your rationale and/or proposed changes:

Comment on Treatment of Certain Latin Letters as Potential Confusors The Initial Report deliberately limits its scope to Latin characters that are Unicode-decomposable into an ASCII base character plus combining diacritical marks. While the rationale for maintaining a narrow scope is clearly articulated, this technical framing results in the exclusion of certain Latin-script characters that are demonstrably relevant to the PDP’s stated objective of mitigating end-user confusion. In particular, we wish to highlight the Scandinavian letters æ and ø, and the Sami characters ŋ and đ as cases that warrant explicit analytical acknowledgment. æ and ø Although æ and ø are not Unicode-decomposable, their exclusion on purely technical grounds leaves unaddressed a well-established pattern of real-world usage that directly affects user perception. In particular, ø is widely used by English-speaking users as a stylized form of “o”, often with no awareness that it represents a distinct letter in Nordic languages. This practice is common in branding, usernames, and informal writing, and occurs independently of linguistic competence. As a result, ø routinely functions in practice as a visual substitute for “o”, undermining the assumption that non-decomposable characters are categorically less confusing to end users. From an end-user perspective, the distinction between “Unicode-decomposable diacritic” and “non-decomposable letter” is not meaningful. What matters is visual similarity, expectation, and usage context. ŋ and đ The same concern applies to ŋ (eng) and đ (d with stroke), both of which are excluded from consideration under the report’s Unicode-decomposability criterion. In practice, ŋ is frequently perceived as a stylized or modified form of “n” or “g”, depending on typeface and context, while đ is commonly perceived as a stylized “d”. These perceptions are especially prevalent among users unfamiliar with the linguistic role of these characters, and they are reinforced by their use in branding, typography, and informal visual contexts. As with æ and ø, the exclusion of ŋ and đ rests on a technical normalization property rather than an assessment of how users actually interpret these characters in domain names. Implications for the Final Report The Initial Report relies heavily on Unicode normalization as a gating mechanism for policy consideration. However, Unicode-decomposability is not a proxy for user perception, nor does it reflect how users actually encounter and interpret characters in domain names. As currently framed, the report risks conflating a necessary scoping constraint with an implicit substantive conclusion. In particular, the absence of engagement with æ, ø, ŋ, and đ—despite their demonstrable real-world confusability—creates a policy blind spot that is difficult to reconcile with the PDP’s stated objective of mitigating end-user confusion. At a minimum, the Final Report should make clear that the exclusion of these characters is a function of scope and technical framing, not a determination that they do not present confusion risks at the top level. Without such clarity, there is a risk that the report will be read as implicitly dispositive on issues it has not, in fact, examined.