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Dot Eco LLC's comments on the draft 2 of application guidbook

  • To: 2gtld-guide@xxxxxxxxx
  • Subject: Dot Eco LLC's comments on the draft 2 of application guidbook
  • From: Fred Krueger <frkrueger@xxxxxxx>
  • Date: Mon, 13 Apr 2009 12:34:49 -0700

Dot Eco LLC, an organization backed by Al Gore, the Alliance for Climate Protection, The Sierra Club and Surfrider commends ICANN for a well thought out and comprehensive plan to overhaul the new Top Level Domain system. We think the plan is necessary for a number of reasons:

First of all, the .COM namespace is now extremely over-crowded. Despite a lowering of retail registration costs to around 10 dollars per name, the true cost of obtaining a reasonable domain name for a new company or individual is in the thousands of dollars, or higher. For example, the domain "skiresorts.com” was auctioned off last year for eight hundred and fifty thousand dollars, while a less desirable string “digitalgreetingcards.com” sold for two thousand dollars. Furthermore, the process of obtaining a domain in the secondary market is often an extremely time consuming activity. It can take months of negotiation, and the use of specialized domain name brokers in order to negotiate the sale of a generic, or even non-generic word. We believe that the opening up of the TLD space will allow registrants, for the first time, to be able to obtain reasonable domains at a reasonable price.

The second reason the plan is necessary is to allow multiple legitimate trademark holders to own their own trademark in a TLD that is relevant to the industry in which the trademark holders operate. For example, United Vans might own united.vans while United Airlines might own united.air. As the new process is rolled out, domain holders will self designate themselves under each of these top level extensions.

The third reason we like the plan is from a consumer perspective. We believe that the addition of a specific top level domain such as ".eco" will help users and search engines differentiate between sites with a ".eco" "labelling" that aim to serve an eco-friendly purpose, versus other sites. The new TLDs will focus the meaning of URLs - as opposed to creating confusion, as some have claimed.

Overall we think the draft applicant guidebook is a huge step in the right direction. However, we have comments on how it might be improved. Specifically, we have comments surrounding the areas of review committees, community status, contentions sets and auctions

1. Review Committees. We feel that to ensure unbiasedness the review committee should be selected in a random fashion. There should be also more information on WHO is going to be on panels, and panel member conflict of interest guidelines should be published. Panelists should be required to specify and publish COI. Finally, review committee members should be reviewed for conflict of interest and a person who is specified a COI must be replaced with another person who must have no COI.

2. Community Status. We support Minds and Machines’ position that in order to achieve community status a score of 12 should be sufficient.

3. Contention Sets. We would like ICANN to provide simple examples of whether 2 strings would be classified as contentious based on meaning. For example, would ICANN view “.car” as colliding with “.auto”?

4. Auctions. We feel that there needs to be mechanisms implemented to ensure the legitimacy and sincere interest of individuals competing in an auction. We suggest that this can be done by requiring that the funds be escrowed in advance of an auction to validate the ability and real interest of each party to win the top level domain. We support Minds and Machines proposal that each party in an auction should pay a small percentage (20%) of each bid increment to ICANN. For example of every $10,000 more the bid is raised, the winner and loser must pay $2,000. The objective would be to discourage artificially driving up the price by parties and encourage them to resolve matters.

5. We support Demand Media’s rapid takedown proposal and Bart Lieben’s trademark validation database thoughtful proposals.

ThWe thank you for your consideration of the aforementioned changes to the current guidelines.


Fred Krueger, Dot Eco LLC


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