The RrSG supports this Recommendation that the “same entity” principle applies to the allocation of future variant domain names, and would raise some practical considerations regarding this principle. How does a registrar know that a domain is an IDN variant? How is a registrar to know that a source or variant domain is already registered with another registrar? When an IDN source or variant domain is registered, can the registrar access a list of other variants which are available at that time? These questions may all be answered with a technical solution such as an EPP extension.

In this scenario the registry would need to keep track of what domains and variants exist, as the registrar would not have access to that information.

This is a very important recommendation, especially when considering the security risk presented by homographs. The minimum IDN variant deployment requirements should be developed with input from registrars, as registrars have experience which may assist the process.

The RrSG supports the recommendation that the source domain name must be jointly determined by the registrant and the sponsoring registrar. Typically the first domain registered would be the source while subsequent registrations are variants, however some registrars would prefer to allow the registrant to change which domain is considered as the source domain. In the case of an expired source domain, the registrant should be able to designate an alternate source rather than lose the remaining variant domains.  

The RrSG strongly supports the creation of a service which allows indication of the source domain of a variant set as well as discovery of allocated variant domain names. This could be done as an EPP query to a registry service. 

The RrSG supports the recommendation to formalize and document the process for developing and updating the IDN Implementation Guidelines, expanding responsibility for maintaining Guidelines to the Community.

C3 Charter Question: The RrSG understands that either Model 1 or Model 2 may be preferable depending on the given situation. As such, there should always be clarity regarding which Model is in use for a TLD, in order to avoid confusion.

C4 Charter Question

The RrSG supports the EPDP Team’s conclusion that “variant domain names under any gTLD should not be required to act, behave, or be perceived as identical” and notes that ICANN Policy should not stray into issues of content regulation. 

The Registrar Stakeholder Group (RrSG) welcomes the opportunity to provide a comment on the Phase 2 Initial Report of the EPDP on Internationalized Domain Names. This is a significant undertaking by the ICANN community and ICANN Org, and the RrSG appreciates the dedication of the team in addressing this important matter.

The RrSG supports the recommendations in the Phase 2 Initial Report. Equitable access to the Internet and participation in the Domain Name System includes the ability to use one’s own alphabet in a top-level domain or registered domain name; the Recommendations and Implementation Guidance provided in this Phase 2 Initial Report support this principle and will thus provide a benefit to the Internet as a whole. 

We note the importance of ensuring that any approved IDN policy includes a realistic and practical ability for registrars to implement the Recommendations and follow the Implementation Guidance, including the ability to identify variants and smoothly interact with the registry to provide DNS services in IDNs. As popularity of IDNs increases so does the potential for deceptive domains (“homographs”) which must be carefully monitored and guarded against.