eco - Verband der deutschen Internetwirtschaft e.V.: Comments on the 2nd Draft Applicant Guidebook

["Thomas Rickert - eco e.V." <rickert@xxxxxxxxxxx>]

The below comments are made on behalf of the German Internet Industry.
eco is the German ISP and Internet Industry Association with about 430
members from different Internet industry sectors. The eco association
represents over 200 ISPs and Registrars forming the backbones of the
German Internet.

The comments have also been sent as a letter from eco CEO Harald Summa
to Mr. Twomey as a follow-up to the letter of February 4th, 2009.


*Comments on the second draft Applicant Guidebook*
 

In addition to the questions raised in our letter dated February 4th,
2009, we would like to comment on the second draft of the Applicant
Guidebook as follows:
 

*- Application fees and annual fees* 

According to feedback we received from various stakeholders, not only
bigger cities or companies are interested in their own TLD.  

The application fee amounting to US$ 185,000 and the minimum US$ 25,000
annual fees seem to unduly discriminate e.g. smaller cities or regions.
As a result, the incumbent gTLDs and ccTLDs may be protected from
competition, which should not be in the interest of ICANN’s mission.
Additionally, the high fees distort the business models and policies for
the majority of the new gTLDs and thereby prevent competition in the
global and local name space. Some good new gTLD ideas might not even
have the chance to start with such high financial burden upfront and
periodically. Therefore, we request ICANN to lower the allover fees for
the first 3 operational years of new gTLDs to not more than US$ 100,000
including the application fee.

*- Multiple strings*

The German language contains “Umlaute”. According to the Applicant
Guidebook, initiatives, which intend to apply for a TLD need to choose
one string, either with or without the Umlaut. This practice will
confuse parties that wish to use e-mail addresses or to find websites.
We therefore recommend that an application can comprise more than one
string with and without the Umlaut at a reduced application and annual
fee since the operation of the registry will be the same. The same would
need to apply to abbreviations of city names or names of regions.

* *

*- Public bodies*

 Currently, no distinction between private and public bodies is made
when it comes to proving e.g. financial viability. The assessment of
public bodies should be less cumbersome than for private bodies, which
could and should result in a reduction of the costs.

*- Timeline*

 New initiatives need to carefully plan their budgets and to provide
investors and sponsors with reliable timelines.

 Over the past three years, ICANN has not been able to meet most of the
timelines published with the development of the current new gTLD round.
The possibility to apply for a new gTLD has been constantly delayed from
2007 and is now announced for early 2010. We recommend that ICANN should
consider potential detrimental effects on its credibility and the
aforementioned disproportional economic burden on organizations
developing ideas and business models for new gTLDs. Therefore, eco would
very much appreciate if ICANN could publish a definite date for the
application window no later than at the meeting in Sydney in June 2009.


The above comments and concerns result from a number of inquiries from
at least a dozen German Internet enterprises, eco members and other
parties, which are interested in applying for a new gTLD.  

Please note that eco strongly supports initiatives and companies in
their aim to successfully apply for a new TLD. Currently, our
association organises a road show in four towns all over Germany to
advise interested parties on the application process, organisational and
technical requirements. In our efforts, we would very much like to be in
a position to provide interested parties with answers to the questions
and issues raised in this and our last letter.

-- 

____________________________________________________________

Thomas Rickert, Director Self Regulation, eco e.V. (www.eco.de)