DOTZON GmbH on the 2nd Draft Applicant Guidebook

["Katrin Ohlmer" <katrin@xxxxxxxxxx>]

DOTZON GmbH consults companies and organizations how to apply for their own
top-level domain (TLD) e.g., .brand, or .company. We have clients including
German industry leaders (DAX 30 stock market index) and Internet companies.
In this capacity we would like to make comments to the second draft of the
Applicant Guidebook:

1. Reliable Timeframe

Companies need reliability when planning to extend and secure their brand on
the Internet with an own TLD. Many companies in Germany are evaluating this
opportunity. We urge ICANN to expressly state a reliable date for the
application period of the next round. All applicants writing their business
plan are in need of this information, both from a business and financial
planning perspective. Otherwise some, if not many, applications might not be
filed which might be contradictary to ICANNs core values (no 6) of
"Introducing and promoting competition in the registration of domain names
where practicable and beneficial in the public interest". 
We also urge ICANN to stick to the goal to begin with the next application
round within one year after the forthcoming round is completed. This will
help potential applicants to develop their respective operating models in a
reasonable timeframe and should help to reduce some of the pressure expected
for the start of the next round.

2. Registrar agreement for company TLDs
 
A company might want to run a TLD like .company or .brand targeting only a
certain community (www.ceo.company, www.applications.company,
www.product.company). This TLD shall be applicable to use just only one
ICANN-accredited registrar.

3. IRT - Interest Disclosure Statement

We fully agree that ICANN decided to take a closer look at the different
mechanisms to protect trademark holders in the new gTLD process and to
respect the needs of this stakeholder group. Nevertheless we would have
appreciated if members of the IRT were obliged to submit an interest
disclosure statement regarding their interests in the new gTLDs as is common
practice in ICANN stakeholder groups (referring to ICANN Bylaws, Article III
"ICANN and its constituent bodies shall operate to the maximum extent
feasible in an open and transparent manner.").

4. Community-based vs. open applications

Companies who file their application for .brand or .company should be open
to decide if they apply for an open or community-based namespace.


Best regards,

Katrin Ohlmer
CEO
DOTZON GmbH, Berlin, Germany
www.dotzon.com