[governance] Is really Bulgarian Cyrillic .бг (.bg)? - Recommendation

[Louis Pouzin (well)]

The .бг story is very well analysed in previous postings by Daniel, and
need no more explanation. To sum up, ICANN is resorting to well known
dilatory tactics to elude its responsibility, and snow the issue.

In particular, the theory of "confusingly similar" ccTLD strings is a
typical maneuver to divert attention from a more fundamental principle
established in the UN WSIS Summit 2005 by the Tunis Agenda (TA), which
reads:

*« 63. Countries should not be involved in decisions regarding another
country’s country-code Top-Level Domain (ccTLD). Their legitimate
interests, as expressed and defined by each country, in diverse ways,
regarding decisions affecting their ccTLDs, need to be respected, upheld
and addressed via a flexible and improved framework and mechanisms. »
*
This is crystal clear. It is none of ICANN business to argue on Bulgarian
.бг.

The USG has signed the TA. Was it just a scrap of paper ? It was not.
Article 63 of the TA was worded in a way China wanted it, because she had
already implemented Chinese TLDs. USG and ICANN had to accept the fact.
There was nothing they could do, except pretending that Chinese names were
just a minor twig subordinate to the ICANN DNS. A non event, sort of.

So, *acccording to TA, picking a cyrillic ccTLD is for Bulgaria to decide,
and none other*.

Presumably ICANN does not see Bulgaria as a significant political actor,
like China, and doesn't care much of Bulgarian wishes. Hence an easy
opportunity to creep into a not well guarded territory, to expand its
illegitimate monopoly. Familiar ICANN tactics, isn't ?

At this stage it is clear that playing cat and mouse game with ICANN on
silly arguments is a waste of time.

Perhaps Bulgaria could write a letter to DOC, and remind them of the USG
signature on the TA. It would be useful to get a response, even if it is
plain fuzzy. But no response would also be significant.

Or ICANN could shift tactics and say "no objection to .бг, but it won't be
in the ICANN root". If so, this position should be expressed in writing.

Bulgaria is a member of the EU. Commissioner Neelie Kroes would certainly
be interested in this story, because there are dozens of non latin
languages in the EU, and she is not enthusiastic for abusive monopolies.
She might even come to a conclusion that a European root would make sense.
- - -

On Fri, Nov 4, 2011 at 09:16, Daniel Kalchev <daniel at digsys.bg> wrote:

>
>
> On 04.11.11 07:38, Imran Ahmed Shah wrote:
>
>  Dear Friends,****
>
> ** **
>
> *Context:*
>
> Actually, the visual resemblance of TLD string had not been studied
> thoroughly and precisely in early stages, when the ccTLDs were being
> allocated with ASCI codes (Latin Characters). That is why the 18 ccTLD
> script has confusing similarity in visual text with each other.
>
>
> Not exactly...
> The reason these strings have "similarity" problems is because, these
> strings are listed in an internationally accepted list of country codes.
> Those who accepted the list and the "possible confusion" are way, way
> larger and more important in this world than ICANN. In this sense, ICANNs
> stance on this matter is simply arrogant.
>
> The use of existing two letter country codes as ccTLD strings was a
> decision made long before ICANN existed and has never been disqualified.
> Apparently, such existing similarity, within the same (ASCII) script has
> not led to any instability for Internet nor impacted it's security.
>
>   However, this kind of study become the focus  of the DNS stability
> teams when the IDN ccTLDs were being introduced and they had to exercise
> their authority for the refusal, easily say, No. According the Fast Track
> they do not have liability and responsible to justify their decision or
> recommendations to the public.
>
>
> This is correct. The expert panel says: "We were given specific
> instructions by ICANN and for this given input, we are supposed to produce
> this output". ICANN says: "we did not make this decision. We gave the
> application to the stability panel and they said no".
> The specific "instructions" are kept secret. I could speculate that
> today's ICANN staff may not even know what they were.
>
>   That is why, confusions are being developed among public and technical
> community trust on the transparent decision making process of the ICANN.
> Internet recognized by ASCI codes (Latin Characters) and simply Cyrillic .бг
> has resemblance with Latin .6r (digit six + r). I also underact that
> Bulgarians would not like leave the abbreviated string by selecting
> alternatively full name of the Country in Cyrillic Language script.
>
>
> It is interesting to note, that digits are not permitted as TLD names.
>
> It is also interesting to note, that until recently, everybody was talking
> about .бг and .br, now more and more talk about .бг and .6r.
> Perhaps because we already pointed out that the UNICODE table of
> confusable characters do not list any match for the Latin 'r' and a
> Cyrillic character.
>
>  ****
>
> ** **
>
> *Review on Requirement Analysis:*
>
> Now, my question is with the Bulgarians Internet Community that do they
> really want to go for the cyrillic language script and feel much benefit
> out of it by having Cyrillic .бг in parallel to the English .bg then what
> is the solution? (because in Korea, the Korean Internet community do not
> feel much benefit and advantage to have domain names with IDN ccTLD with
> Korean Language). And I believe that the public and technical communities
> and ICANN are unaware with the future (upcoming) prospects and potential of
> the failures of IDN TLDs framework.
>
>
> During my talks with ICANN staff on the subject, I raised the point that
> one should look in perspective. In the past, it was viewed that IDN TLDs
> should not be similar to ASCII TLDs. However, reality is that the Latin
> alphabet on which ASCII is based is actually an minority alphabet. The use
> of other alphabets is more significant and as Internet becomes more and
> more "internationalized" (which is rather poor choice of terminology, by
> the way), ASCII labels will have less and less importance. What is more,
> ICANNs own great new IDN gTLD initiative will spring a lot more IDN new
> TLDs than ASCII TLDs.
> So at some point things will be actually reversed and ASCII TLD
> applications will have to make sure they are not similar with some other
> script's characters. Why not Cyrillic... ;-)
>
> Some background:
> I am obviously with the BG ccTLD Registry. As such, in theory I should,
> according to some people, have no interest in supporting the development of
> an IDN ccTLD for Bulgaria. That is of course speculation. Cyrillic is
> deeply involved in the Bulgarian culture -- some even go that far to claim
> that Bulgaria is the originator of the Cyrillic script.
> Further, the abbreviation "БГ" is how Bulgarians identify the country in
> our own language. There was no other Cyrillic abbreviation in use for that
> purpose, ever.
>
> When the IDN Fast Track process started, we initiated a number of pools in
> Bulgaria to inquire what the community opinion on the best IDN ccTLD would
> be. All previous pools were more or less informal and it was always 'БГ".
> These pools were formal this time. I am aware of three big pools: one done
> by the BG Registry (you can see the results on https://www.register.bg),
> another done by the Bulgarian Government and yet another done by the Uninet
> Association (who were experimenting at that time with a .бг in alternate
> root environment). The pool made by Register.BG was to all BG TLD contact
> persons -- therefore anyone who has had anything to do with a BG domain
> name. Therefore, we consider it most representative of the "community
> opinion" and it is somewhat related to your question. The pool by the
> Government wasn't very popular in participation, perhaps due to the short
> time frame an d lack of enough publicity. All pools suggested the prevalent
> choice being '.бг' and therefore this is why such application was made.
>
> Later, when the applicant was informed of the expert panel opinion, there
> was a second pool made by the Government, with the special question "what
> OTHER string you prefer". The response was overwhelming, this time with
> much greater participation. The prevailing majority of answers were:
>
> - we want .бг.
> - if we are not going to get .бг, we do not want any IDN ccTLD.
>
> With this public opinion, it is understandable that our Government are not
> looking for any other option anymore.
>
> More specific on your question:
>
> It was always assumed (at least by Register.BG) that all delegations under
> a Cyrillic TLD will be in Cyrillic. This is the whole point to have a
> Cyrillic TLD: to be able to type the entire domain name in Cyrillic. You
> already can register IDN domain names under the ASCII BG, such as
> президент.bg <http://xn--d1abbgf6aiiy.bg> (president.bg), but these are
> not extremely popular, primarily because everyone now knows that you can
> have IDN.IDN names and.. sort of wait for this to happen (ICANN to sour our
> their internal confusion).
>
> In respect of the pending application and eventual assignment of .бг,
> Register.BG has made a proposal to the Government, that should both TLDs be
> handled by the same registry, a form of 'bundling' may be appropriate, for
> example if one registers президент.бг they get президент.bg<http://xn--d1abbgf6aiiy.bg>,
> subject to the applicable restrictions under BG of course: that is, you (at
> least under current rules) cannot have око.bg <http://xn--j1ahb.bg> (око
> being in Cyrillic).
>
> It is also interesting to note, that for many years, registries that have
> implemented IDN registrations, restrict the possible labels so that no
> string confusable labels are possible with (say) Cyrillic and ASCII
> characters. But note: this only applies to exact character match, not to
> "possibly similarly looking in some font". It is sad this is not the policy
> at the root level as well.
>
>  ****
>
> ** **
>
> *Recommended Solution:*
>
> In order to resolve this conflict I do not understand that appealing to
> ombudsman could resolve the conflict, because they provisioning allows to
> refuse. I would recommend that Internet Community and Internet Governance
> supporting organizations should write to the ICANN Board and requesting
> them to authorize ccNSO and GNSO with a mandate to develop a Working Group,
> and that working groups would address these issues and to sort out the way
> to compensate IDN TLDs applicant’s to promote Internationalized Domain Name
> System. And the allocation of the Cyrillic .бг string may be allowed with
> the recommendation of that specific working group to the board of ICANN.**
> **
>
>
> This has already happened. In a very ICANN-ish way...
>
> On the San Francisco ICANN meeting, when it became clear that not only the
> Bulgarian case is halted, but also the Greek application and also the EU
> IDN application in Bulgarian and Greek (Bulgarian and Greek as well as the
> Cyrillic and Greek alphabets are official within the EU and according to
> the "EU law" are to be fully supported). Then, a sub-working group was
> created under IDN ccPDP WG1 to produce suggestions to ICANN how to handle
> these cases.
> That working group eventually reported at the Dakar ICANN meeting... on
> the EU case only, stating in effect (you will excuse my imprecise citation)
> "well... we found out that those strings are confusingly similar, but it
> appears that they are confusingly similar with one another (?). We also
> discussed the matter with EURid (the EU registry) and agree that as long as
> they register only Cyrillic names under the Cyrillic TLD and Greek names
> under the Greek TLD, everything is fine. Therefore we recommend that ICANN
> approves this application.."
>
> Double standard? Why the Bulgarian and Greek cases were not considered?
>
> Indeed, it may happen that the full IDN ccPDP process will permit Bulgaria
> to have .бг at some point in the future. This is somehow not dependent on
> ICANN or the 'expert panel' opinions.
>
> But then the question will remain: How come the .бг TLD was, let me cite
> from the 'expert panel' report:
>
>
>
> .. and, in the future it will be less confusable?
>
> Why was then Bulgaria delayed with it's Cyrillic TLD implementation and
> why was all this several years long attempt to undermine ICANNs credibility
> to the community?
>
>
> Finally, I would like to comment thus:
>
> If someone (ICANN in this case) is tasked with the heavy responsibility to
> make a decision in situation like this, effectively permitting or not a
> country's own language/script to be used and they are to consider the
> opinion of an expert panel, with whom they have a contract.. and it is
> apparent, that this opinion is accepted by practically no one, then a
> prudent one (ICANN) will simply seek the opinion of another expert panel,
> or two (to make easier choice). That would resolve any and all doubt. What
> is more, ICANN staff is required to do so according to the Fast Track
> Implementation Plan.
>
> There are all kinds of theories and first hand knowledge why all this has
> happened.. but let's give ICANN chance to fix this stupid situation and
> clear their image, before these things go public.
>
> Daniel
>
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