2nd gTLD Guidebook Comments
- To: <2gtld-guide@xxxxxxxxx>
- Subject: 2nd gTLD Guidebook Comments
- From: "Matt Mansell" <matt.mansell@xxxxxxxxxxxxxxx>
- Date: Mon, 2 Mar 2009 02:17:18 -0000
Please find below our comments (Some more minor than others) regarding
the gTLD Guidebook.
Success Assumption - There is a total assumption throughout the
guidebook that all registries will succeed and if they fail, will be
acquired. This will not be the case with the crowded space that could
result. Registry's will fail and there will not be a buyer at any value.
This is totally against ICANN's mission statement to promote a stable,
secure & interoperable Internet and we are amazed no consideration has
been given to this. The end user will be the loser and total disarray
will result if a registry fails and no-one will take it on. Will ICANN
become a registrar and registry!
Continuation Funding - The guidebook states that the applicant will be
asked to prove 3-5 years funding for continued operation in the case of
failure. This is naive and will simply result in low forecasts from
applicants. Furthermore, when a business fails, it fails because it ran
out of money! It doesn't fail at the point where someone says, hey we
better stop operating now because we only have 3-5 years left in the
bank. This needs much more thought and maybe contractual protection with
deposits etc. Even then, there will be statutory legal issues. How
regularly will/should ICANN review this cash position. With the volumes
expected in the first round, it is a likely scenario that registries
could fail in the first year as the market is flooded with competing
Minimum Registrant Base - One of ICANN's core values is to promote
competition. gTLD's with a single end user (EG: Corporate protective
registration) do not promote competition on the Internet. They create
closed protective registrations arguably making the Internet less
operable to the end user. Maybe a minimum registrant base for both open
and community registrations is one way to evolve this and encourage
2nd/3rd level use with a corporate registration.
Language - In general we felt the guidebook was far too loose. Terms
such as "As soon as practical", "certain elements", "Satisfactory" and
many other are common place, undefined and too subjective.
Public Comments - ICANN affording DRSP's the discretion to consider what
public comment to hear and what not to, does not promote consistency or
fairness across applicants. The decision to allow them or not should not
be taken at this level.
Auctions - Is it fair to auction off a community application? Assuming a
community application does evolve into just that (And not a corporate
registration) then an auction conclusion is not in the spirit of the
Internet. It will favour financially stronger community organisations
over those that maybe should take that preferential position on the
Internet for their cause.
You're on your own. 1.2.4 - ICANN stress in great detail in this section
that although they will delegate the TLD, this cannot force software
manufacturers etc to support that TLD. ICANN need to accept that their
core mission statement is to make the Internet Interoperable, stable and
secure. If they are not prepared to work with new gTLD applicants to
ensure their new TLD is accepted top down, then this questions their
entire mission statement and the gTLD programme persay. If ICANN want to
pursue new gTLD's on such a vast scale, then they have to accept, plan
and budget for work across the community to ensure their acceptance
keeps the Internet operable.
Credit Card Processing (126.96.36.199) - ICANN will accept up to 20K on a card
with no processing charges. This isn't common place in today's world and
the membership should not pick up the tab for their acceptance of cards.
X% should be charged on top for those wishing to pay by this means.
FX Payment (188.8.131.52) - ICANN wishes to separate from their US
Government agreement in order to be more global. However, they will only
allow payment in USD. In the current climate in particular FX loss/gain
can change a business plan overnight. This isn't a global strategy and
ICANN should at least support the top 3 global currencies natively.
String Evaluation - HSBC/HBOS examples are simply going to encourage
early protective registrations that won't be used. There is no semantic
relevancy to ICANN's direct comparative string evaluation and there
maybe should be. Its open to interpretation of a review across all
others. If 20K applications are received, how can ICANN be sure an
Examiners review will be comprehensive with such a vast list to review.
Reserved Names - Is .web deliberately missing! It strike us there will
be endless open and community applications for this TLD, generating
substantial auction value. It should be retained by ICANN for future
Objection languages - If ICANN is global is it fair to insist
objections, responses and dialogue should all be conducted in English.
English isn't the world's most spoken language and multiple languages
should be permitted if ICANN is to develop its integrity globally.
Mesh Digital Ltd
Tel: +44 (0)1483 304030
Fax: +44 (0)1483 304031