Name: Bill Jouris
Date: 17 Nov 2021
Original Public Comment: Proposal for Latin Script Root Zone Label Generation Rules
1. Overall, does the proposal meet its goal of defining Internationalized Domain Name (IDN) labels for the Latin script that are suitable for the root zone?
If you selected no, please explain why.
There are serious flaws in the draft, as discussed below and indicated in the attachment. References to the IDN foundational documents are included there.
2. In your view, are there any required technical changes to the proposal? Please list them and include explanations.
A minority report regarding the proposal is attached.
Summary of Attachment
There are issues both with the Repertoire, and with the evaluation of possible Variants. These are detailed in the attachment.
Summary of Submission
The Proposal has two types of problems, as detailed in the attached Minority Report. First, almost half of the languages which use the Latin script were excluded when creating the Repertoire. This runs directly counter to the reason for the IDN project. Second, the evaluation of variants assumes a level of expertise among end users which exceeds that of the experts on the panel. That is, there are cases where a majority of the experts found a pair of letter difficult to impossible to distinguish. But the Panel's official position is that a "reasonably careful user" would notice the difference, and realize that the domain name was not the one he was expecting. Instead, the Panel should identify variants in a way that reflects the far lower level of expertise of users who are not trained linguists or other expertise on the script.
In addition, there are a couple of issues where the Panel necessarily followed guidance from higher up in the IDN project. But said guidance does not accurately reflect the reality of end users' experience and behavior. The Panel should at least raise these issues, even if it does not have the authority to change them.