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Message from ALAC to ICANN

Date: Fri, 7 Nov 2003 21:15:36 +0100
From: Thomas Roessler
To: Barbara Roseman
Cc: Vittorio Bertola
Subject: New registry services / constituency statements

Individual Internet users can be affected by the introduction of new registry services in several roles: As registrants, they are affected by services that change the registration system, and by services that might affect their ability to reach an intended audience online. As "DNS consumers", they are affected by changes to DNS behavior.

Individual Internet users are also affected by indirect effects that the introduction of new registry services (or, likewise, a failure to introduce such services) might have: A registry service not introduced might be a valuable offer that is not available to Internet users. A registry not able to operate in a commercially viable manner may damage its registrants. A TLD market that is commercially attractive for new operators will give Internet users more choice in the long term, and will enable competition. A registry service that moves choice from the network's edges to its center, though, means less choice for users, and will replace competition at the network's edges to its center, though, means less choice for users, and will replace competition at the network's edges by a monopoly at the center. A change to DNS behavior that specifically targets a single application-level protocol may improve user experience in the short term, but will harm innovation in the long term.

These examples demonstrate that there is no simple and universal way to answer the question whether some specific new registry services should be introduced, by whom, and how.

In very general terms, we would argue that the introduction of new registry services should be permitted unless publicly detrimental.

As far as the implementation of this general principle is concerned, we limit our comments at this point to some preliminary and basic observations:

  • Any decision about the introduction of new registry services should be based on well-defined, objective criteria that must be applied in an even-handed manner. This should not prevent ICANN (or whatever entity is chartered with evaluating proposed registry services) from taking possible market dominance of the party that proposes a registry service into account.
  • When a new registry service is both deliverable at the network's edges and at its core, then preference should -- in general -- be given to delivering this service at the network's edges, in order to foster user choice and competition. (See issue 6.6 from the staff manager's draft report.)
  • The introduction of a new registry service should not create a situation in which commercial gain at the center comes at cost that is incurred by parties at the network's edges, without giving those who incur the cost a choice about it.

We appreciate the opportunity to comment, and look forward to further contributing to the development of a fair and objective process for assessing new registry services.

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."