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Message from Ross Wm. Rader to Barbara Roseman

Date: Fri, 14 Nov 2003 10:15:49 -0500
From: "Ross Wm. Rader"


I write to you on behalf of Tucows Inc. and those registrars that chose to provide me with the feedback I solicited in my message to the Registrar Constituency of November 4, 2003 (<>) concerning your draft report, "Excerpt from Draft Version of Staff Managers Issues Report for the Development of a Process for the Introduction of New or Modified Registry Services". This communication is not an official communication of the Registrar Constituency and should not be viewed as such. Thank you in advance for taking the time to review these (late) comments concerning your report excerpt.

The excerpt is quite comprehensive and will likely serve as a useful basis for discussion and resolution of the issues you have identified. There are however three items of specific interest to registrars that you may wish to consider for inclusion in your document;

  1. Specifically determining the definition of a "registry service". This is very unclear to the registrars that I spoke to and will be the lynchpin in any discussions moving forward. There is a strongly held belief held by members of the constituency that there needs to be a distinction drawn between the evaluation of services that benefit from the registry having exclusive access to the TLD database and those that do not.
  2. Clarifying the intended nature of the registry contracts. This is not so much a matter for the policy development process, but rather, a statement that the ICANN Staff or Board can make to clarify whether the existing registry contracts are, as one member put it

    "...intended to be in the form of an outsourced arrangement where a registry operator provides a specified service (e.g domain name registration) for a specified price (e.g $6) for the ICANN community, OR is the registry agreement intended to be in the form of a licence right to operate a particular TLD and generate revenue based on the services possible from such a role (subject to some maximum price controls on core services)?"

  3. First examining the question of whether or not new registry services should be introduced prior to examining the question of how new registry services should be introduced.

We would appreciate specific clarification on each of these questions.

Given that a significant portion of the policy development process is analysis, we must ensure that we promote a complete and thorough analysis of the salient issues. The answers to each of these question will shape the nature of the policy development discussion on a very fundamental level and it is imperative that the community proceeds with the policy development process with the context that answers to these questions can provide. We therefore strongly urge that these matters are considered in some way by your report.

I thank you again for your time and attention to this matter. Please do not hesitate to contact me if you require further clarification regarding the issues that I raise with this message.

Warm regards,

Ross Wm. Rader
Tucows Inc.

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."