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Message from Edward G. Viltz to Vint Cerf

From: Edward G. Viltz
Sent: Tuesday, November 21, 2006 5:11 PM
To: Vint Cerf; Paul Twomey
Cc: John Jeffrey; PIR Board; David W. Maher
Subject: PIR Application for Approval of Excess Delete Fee and Response to Letter from the INTA


In the interest of time, this letter is being sent via email. Public Interest Registry (PIR) is writing in response to a letter of November 16, 2006 addressed to you by the International Trademark Association (INTA). PIR has a pending application before the Board of Directors of ICANN to amend its Registry Agreement to provide for an "excess deletions fee" on certain .ORG domain names deleted during the 5-day add-grace period (the "Proposal"). The INTA letter mischaracterizes this as a proposal to amend the "Registrar Accreditation Agreement" (sic) "in order to reduce the number of instances of what has become known as 'domain name tasting'".

The PIR Proposal makes it abundantly clear that it is not intended to address the phenomenon known as "domain tasting", nor is it intended to resolve all the problems that have arisen in connection with the 5-day add-grace period. PIR has not taken a position pro or con on domain tasting. Furthermore, it may well be that there are reasons to amend, improve or even abolish the 5-day add-grace period, but the PIR Proposal does not address these.

The PIR proposal is a straightforward attempt to deal with a problem that has arisen from certain abuses of the 5-day add-grace period in the experience of PIR. It is not offered to the Internet community as an endorsement of domain tasting or as a model for other registries (although PIR would have no objection to its adoption by other registries).

PIR believes that INTA is entirely free to adopt a position opposed to domain tasting, but that position should not be leveraged to interfere with the pending PIR Proposal.

PIR urges you and the Board of ICANN to approve PIR's Proposal as currently scheduled on the agenda of the Board meeting on 22 November.

Respectfully submitted,

Edward G. Viltz

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."