Thank you for your comments!
Below you find the list of replies this PDP has had from letters sent out in February and March 2014.
And here you find the collation of all comments received, grouped into the eight questions the WG sought feedback on.
Please bear in mind that a future replacement of WHOIS is likely to support non-Roman scripts.
The following is the table of community input and the WG responses to them as of 21 May 2014: Public comment review tool T&T - 21 May2014.doc
NEW: ALAC statement
European Commission
From an e-mail sent to the T&T list by Chris Dillon on 12 Feb., 2014.
Background
Linda Corugedo Steneberg is Director of the European Commission's Communications networks, Content and Technologies Directorate-General, DG CONNECT Cooperation, Directorate D. The EU manages .eu in all languages of the EU, including Greek and Bulgarian, including the registration of domain names.
"Registrants should be given the opportunity to submit data to the Registrar in his own language when registering a domain name.
From our experience, there might be extra costs for some of the involved parties (like the Registry, the Registrars and/or ICANN in the GNSO environment), but that should be budgeted in the ultimate interest of the end users."
It would be worth knowing exactly what those costs are for (transliteration or translation, which fields, verification etc.) and how substantial they are. There are also suggestions about who pays, i.e.
"Registries should bear the cost of translation and transliteration of Registrar data, and Registrars should bear the cost of translation and transliteration of registrant data. As indicated above, this is the cost of making business. The additional cost should be budgeted in the interest of end users. The transliteration and translation should not have, in any case, an effect on the final price that Registrants bear."
The last sentence may not necessarily be the case if the registrars and registries are for some reason not able to subsidise the increased costs foreign language work will cause.
A homogeneous WHOIS (i.e. IRD) resource is quoted as a benefit of transliterating/translating. Using a common language facilitates registration when registrants do not share one. Consultation of data by law enforcement et al. requires a common language. These benefits should be added to our wiki as answers to some of the questions.
"Registrants would have full rights when it comes to respect for multilingualism" would mean that registrars would need to be able to process applications in a wide range of languages, in this case it's the EU languages. It could be argued that this is a special case and that many registries would not need to process applications in such a wide range of languages. It may be useful to think through some scenarios, for example, involving applications for domain names in scripts applied for in countries where there is little experience with the script in question.
"Validation will be more cumbersome provided there is no translation or transliteration" What is being validated? That the non-ASCII label is what it says it is, or that the transliteration/translation is correct?
Thailand
De : Wanawit Ahkuputra
Envoyé : mardi 25 février 2014 10:22
À : Glen de Saint Géry
Cc : gnso-secs@icann.org; Lars Hoffmann; GAC Secretariat; Hugh Thaweesak Koanantakool; Pitinan
Objet : Re: Input Request:Translation and Transliteration of Contact Information Charter Questions
Dear GNSO Secretariat;
Reference made to your letter on 5 February 2014: Input Request: Translation and Transliteration of Contact Information Charter Questions. On the role of our official position as the GAC Representative of Thailand to ICANN and Deputy Executive Director of Electronic Transaction Development Agency, Ministry of Information and Technology, Royal Thai Government; and also the fact that we had been participated as individual memberer in Charter Drafting Team of Translation and Transliteration of Contact Information PDP working group. We would like to give some thoughts and express our opinions on this issue for the Working Group as follow:
Input Request
Translation and Transliteration of Contact Information Charter Questions
Whether it is desirable to translate contact information to a single common language or transliterate contact information to a single common script.
Reference from http://www.academia.edu/3830294/English_as_a_Lingua_Franca_in_Thailand_Characterisations_and_Implications
“ Given that Thailand does not have a history of colonisation by the British and that English is not an official language in the country, Thailand is typically classified as an ‘expanding circle’ country (Kachru, 2005) in which English is used as a means of intercultural communication. Importantly such a classification also entails that Thailand is a norm dependent country which does not have its own variety of English and which does not use English for intra cultural communication. While the extent to which this classification of English in Thailand will be questioned in this paper, the expanding circle tag serves as a useful, if simplified, means for distinguishing Thailand from countries which use English as a first language, or as an official second language.
The linguistic landscape of Thailand is often portrayed as monolingual and highly homogenous with government sources claiming that almost 100% of the population speak standard Thai (National Identity Board, 2000). As might be expected this hides a more complex linguistic picture. Other languages including Chinese, Malay, Lao, and Khmer are also spoken by minority groups (National Identity Board, 2000; Foley, 2005) and the majority of the population use one of the four regional dialects of Thai rather than standard Thai (Simpson and Thammasathien 2007).
Nevertheless, given the relatively minor status given to other languages in the country, English forms the ‘de facto’ second language of Thailand. There are a number of domains in which English is widely used in Thailand including: as a compulsory subject in school and in higher education, as a medium of instruction in international education programs, as the language of international organisations and conferences (including ASEAN and ASEAN +3), for international business transactions, tourism, the internet, global advertising, scientific and technology transfer, media (including imported films and music), international safety and international law(Wongsatorn et al 1996; 2003; Foley, 2005)”
From the reference, even English has given the relatively minor status and not being used for intracultural communication, English, however, is the 'de facto' for intercultural communication and international business transactions including the internet. Therefore, It is quite clear that it is desirable to translate contact information to a single common language or transliterate contact information to a single common script and preferable in English.
What exactly the benefits to the community are of translating and/or transliterating contact information, especially in light of the costs that may be connected to translation and/or transliteration?
As the result of using single official language system, most of the contact information used is in Thai and the translating and/or transliterating of contact information form Thai to English has been loosely handling by applicants or data owners. Several government entities handling English contact information by accepting the information given by data owners per se, therefore, it is possible that the English contact information is inconsistent.
In other cases which government bodies need to provide English contact information such as the geographical name of a street. There are several related standards such as 'Romanization' by Royal Institute, 'the list of exception or reserved words' by geographical name committee. The result of adopting these standards appears in the list of geographical names for places in Thailand in UNGEGN (United Nations Group of Experts on Geographical Names). However, the standards are not widely known and it is not mandatory to adopt. Therefore, it is possible that each government entity could use different method for translation and/or transliteration.
From the stated current condition, if the contact information needs validation, it could be a burden trying to figure out the suitable reference, if any. We have no objection with the approach from the Translation and Transliteration of Whois Contact Information DPD Working Group that this issue is tightly related to the role of government. Currently we are under the consideration to provide the infrastructure for translation and/or transliteration as the single registry system. This approach could benefit as in the most accurate reference for contact information in English and the validation could be handled at the most economic cost.
Should translation and/or transliteration of contact information be mandatory for all gTLDs?
We support that it should be mandatory. From the statistic, around one-third of the domain names in Thailand registered with ccTLD (.th) and anther two-third of the names are gTLD, which is open to all ICANN's registrars. Many cases that Thai domain owner registers for a domain name from foreign registrar, as the nature of internet is borderless. Not having translation and/or transliteration mandatory for all gTLD would create discrimination to registries and registrars.
However to minimize the impact to the cost bearer, the translation and/or transliteration of local language to common language should be established in each country. And this methodology should be accredited by ICANN.
Should translation and/or transliteration of contact information be mandatory for all registrants or only those based in certain countries and/or using specific non-ASCII scripts?
It is unarguable that the translation and/or transliteration should be mandatory for those cased based in non-ASCII script countries. So it is possible that the non-ASCII script countries have higher priority to catalyst this issue.
What impact will translation/transliteration of contact information have on the WHOIS validation as set out under the 2013 Registrar Accreditation Agreement?
Reference to section: Whois Accuracy Program Specification §1(e),
"Validate that all postal address fields are consistent across fields (for example: street exists in city, city exists in state/province, city matches postal code) where such information is technically and commercially feaible for the applicable country or territory."
This could draw to the question of who would make the decision if a country or territory is technically and commercially feasible and what would be the decision making criteria. As the validation of all postal address both newly registered and the backlog could be costly, it might turn out that not many territories or countries is feasible to comply.
Reference to section: Whois Accuracy Program Specification §1(f) and §2
"if Registrar does not receive an affirmative response from the Account Holder, Registrar shall verify the applicable contact information manually"
It occurs in Thailand that more than half of the domain name owners using gTLD and it is possible to choose foreign Registrars. The manual verification might occur when registrar does not receive an affirmative response via email or phone. Even it is not specified the method, this manual verification could costly for Registrar when it is cross-border verification. This also emphasizes the need of single point of registration system for common language/script of contact information for each country. To minimize any cost that might occur during verification, and the more important point is to provide the eligible contact address information.
When should any new policy relating to translation and transliteration of contact information come into effect?
(Reference: http://docs.apwg.org/reports/APWG_GlobaTolPhishingSurvey_1H2013.pdf)
Thailand has been, disappointedly, in the top-5 of phishing for the past several years. From our view, we see that having translation and transliteration pocily in place would be one of the phishing mitigations as the verified contact information would be the important eligible linkage between internet identities to the real person. We encourage that this policy should come into effect at the earliest possible timeline.
Do you have suggestions concerning the basic principles to guide the cost burden discussion, such as the free of charge provision of the information, demand-oriented cost etc.? In particular, the PDP WG is tasked with determining who should decide who should bear the burden translating contact information to a single common language or transliterating contact information to a single common script. This question relates to the concern expressed by the Internationalized Registration Data Working Group (IRD-WG) in its report that there are costs associated with providing translation and transliteration of contact information. For example, if a policy development process (PDP) determined that the registrar must translate or transliterate contact information, this policy would place a cost burden on the registrar.
In compliance with the "Proposal by THAILAND’s Government Advisory Committee (GAC)" submitted into the PDP working group earlier, it is government role to facilitate establishment of the infrastructure for translation/transliteration of contact information. Once the infrastructure is in place, the cost of translation/transliteration and the cost of validation should be economic. This eligible registered contact address information will also be applicable for many other applications for data owner, not limited to ICANN whois database but it could also benefit the e-invoice and all electronic transaction services.
We would suggest considering demand-oriented approach for this matter. In this case, the demand to translate/transliterate and maintain contact address information is belong to the data owners or registrants, and the demand for address validation could be from registrars. Therefore, the cost of conversion from local language into common language should belong to registrants and the cost for validation should belong to registrars.
We are looking forward to gather for a face-to-face meeting during the ICANN Meeting in Singapore.
Regards
Mr. Wanawit Ahkuputra
Deputy Executive Director
ETDA Electronic Transactions Development Agency (Public Organization)
MICT Ministry of Information and Communication Technology
The Government Complex Commemorating His Majesty the King's 80th Birthday Anniversary
120 M.3 Ratthaprasasanabhakti Building (building B),
7th floor, Chaengwattana Rd., Thung Song Hong,
Laksi Bangkok 10210, THAILAND
Tel : +66 2142 1159
Fax. +66 2143 8071
Mobile +669 301 8818
E-Mail: wanawit@etda.or.th
People's Republic of China
De : cuishutian [mailto:cuishutian@miit.gov.cn]
Envoyé : lundi 10 mars 2014 11:27
À : Glen de Saint Géry
Cc : gnso-secs@icann.org; Lars Hoffmann; heather.dryden@ic.gc.ca; guofeng@catr.cn
Objet : Re: Input Request:Translation and Transliteration of Contact Information Charter Questions
Dear colleagues,
Thanks for the request to comment on the Translation and Transliteration of Contact Information. I have communicate and solicit opinions from Chinese Internet community on this issue. I would like to take this opportunity to raise the following points:
- In China the registration info(or contact info) are mainly collected by registrars in Chinese which could ensure the accuracy of the registration info.
- It would be appropriate that the registration info(or contact info) in Chinese script is the basic requirement in the area of China.
- The registry in China should check and verify the Chinese registration info(or contact info).
The globalization of ICANN is made of the localization of the policy and should respect local language and practice. And the intent of Whois is to accurately record and check the registration info(or contact info) and the Chinese registration info can better serve the Chinese community. The Chinese community thinks that the above-mentioned suggestions can be cost-saving and user-friendly for Chinese community.
Best regards,
Cui Shutian
NCSG (attachment)
IPC initial comments (attachment)
FICPI (International Federation of Intellectual Property Attorneys) comments (attachment)
Reply by Chris Dillon (22 December 2014)
