[governance] Is really Bulgarian Cyrillic .бг (.bg) similar to other Latin ccTLDs?

[George Todoroff]

Is really Bulgarian Cyrillic .бг (.bg) similar to other Latin ccTLDs?

	Bulgaria has proposed for an IDN ccTLD the string .бг (Cyrillic
	for .bg, or U+0431 U+0433), but the proposal was turned down by
	the ICANN DNS Stability panel in May 2010 without any arguments
	or an option for appeal.

The proposed string is composed of two characters:
U+0431 CYRILLIC SMALL LETTER BE (б) and
U+0433 CYRILLIC SMALL LETTER GHE (г)

	Reading the tables, provided with Unicode Technical Standard
	#39,
	(http://www.unicode.org/Public/security/revision-04/confusables.txt)
	I see that confusable characters are only:

0431 ;  0036 ;  SL      # ( б → 6 ) CYRILLIC SMALL LETTER BE → DIGIT SIX
    # 

0433 ;  0072 ;  ML      # ( г → r ) CYRILLIC SMALL LETTER GHE → LATIN
SMALL LETTER R # 

	As a result, we see that the applied string .бг could be
	confused only with the string .6r, which does not exist.

The Russian case

	Opponents to the Bulgarian proposal say that Russia first wanted
	to apply for .ру (Cyrillic for .ru), but then selected another
	one, because .ру was found to be confusingly similar with the
	Paraguayan ccTLD .py , and because of this, Bulgaria must be
	obedient and select another IDN string.

	Looking again at Unicode Technical Standard #39, I see that:

0440 ;  0070 ;  ML      # ( р → p ) CYRILLIC SMALL LETTER ER → LATIN
SMALL LETTER P  # 

0443 ;  0079 ;  ML      # ( у → y ) CYRILLIC SMALL LETTER U → LATIN
SMALL LETTER Y   # 

	We have absolute similarity here! Very different than the
	Bulgarian case with 50% similarity.

	Russia selected and received the .рф (Cyrillic for .rf) string.
	Looking for a third time at Unicode Technical Standard #39, I
	see that:

0440 ;  0070 ;  MA      # ( р → p ) CYRILLIC SMALL LETTER ER → LATIN
SMALL LETTER P  # 

0444 ;  0278 ;  ML      # ( ф → ɸ ) CYRILLIC SMALL LETTER EF → LATIN
SMALL LETTER PHI# 

	What do we have here? One similar character, and one not similar
	to a Latin basic character. So, how is this different from the
	Bulgarian case? Its the same! How the Russian string was
	approved, and the Bulgarian – not???


The DNS Stability panel rankings

[6]  Both characters are visually identical to an ISO 646 Basic Version
(ISO 646-BV) character.
[5]  One character is visually identical to, and one character is
visually confusable with, an ISO 646-BV character.
[4]  Both characters are visually confusable with, but neither character
is visually identical to, an ISO 646-BV character.
[3]  One character is visually distinct from, and one character is
visually identical to, an ISO 646-BV character.
[2]  One character is visually distinct from, and one character is
visually confusable with, an ISO 646-BV character.
[1]  Both characters are visually distinct from an ISO 646-BV character.
	
	The panel said that Bulgaria fails under [4] or [5], so the
	string is not accepted, because rank [4] or more is not good.

	But, from my findings here, the Bulgarian (as the Russian)
	strings fail under [2] or [3], and its perfectly fine to be
	approved.

Security proposals

	As another participant in the public comment forum said, two
	security proposals must be implemented:

	“1. All names in the .бг (.bg) IDN ccTLD must be registered only
	with Cyrillic letters.”
	“2. All names in the .бг (.bg) IDN ccTLD must contain at least
	one letter, which can be visually distinguished from the Latin
	alphabet (one of the letters: б, г, д, ж, и, й, л, п, ф, ц, ч,
	ш, щ, ъ, ь, ю, я).” (“г“ may fail off this list, because of my
	findings.)

Examples

	There must be really conservative people in the DNS Stability
	panel, who don`t like seeing domains like:
- раурал.бг because people would confuse it with paypal.br
	Come on, раурал.бг and paypal.br ? Compare with paypal.it and
	paypal.lt ? 

	Others are afraid of seeing:
- руса.бг and pyca.br (whatever this means in Brazilian Portuguese) -
check the second security proposal. The first domain can`t exist.

- - - - -

	Dear DNS Stability panel members, what is wrong here?
	Dear ICANN Board members, Bulgaria needs an appeal procedure!

Cheers,
George Todoroff
-- 
  george_todoroff at imap.cc

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