New gTLD Comments by Alexei Sozonov, Regtime Ltd.

["Alexei Sozonov" <sozon@xxxxxxxxx>]

Comments on New gTLD Applicant Guidebook Version 2

Submitted By: Alexei Sozonov, Company: Regtime Ltd.
Company URL: http://www.regtime.net Date: April 8, 2009
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1.1.5  Please take into consideraton that the application fees is to high for 
the first "1 year" round, and as it was discussed and agreed (and minuted) in 
different ICANN meetings it needs to be cheaper, particularly for IDN 
applications (countries were world money not printed). ICANN should make clear 
statement about what price should  be in this current document to allow 
applicants understand its costs.


1.5.1 (a) Taking in consideration that the process designed to be done online 
automatically (in a main part), it might be fare practice to use the fees of 
third party organizations for the same (as ICANN) work as a reasonable person 
measure for ICANN's cost evaluation.


1.5.1 (b) In our view it's fare and more transparent if Registry Services 
Review Fee will be included in the current amount of Application Fee. 


1.5.1 (c) Again, the Application Fee of $185000 for IDN in many cases is just 
business-unreasonable - say for developing or low Internet-populated countries. 
It fare to create a mechanism to correlate the Application Fee cost with IDN 
countries revenue expectations. 


Respectfully,

Alexei Sozonov

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a.sozonov / vp regtime ltd / sozon@xxxxxxxxx / 1.604.7739204