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Comments on module 1

  • To: <2gtld-intro@xxxxxxxxx>
  • Subject: Comments on module 1
  • From: "Yoav Keren" <yoav@xxxxxxxx>
  • Date: Mon, 13 Apr 2009 00:30:31 +0300

The following are my comments on module 1 of the New gTLD Applicant
Guidebook Version 2:


Section 1.1.5

In order to decrease the uncertainty of the process ICANN should define
an exact date for the second round - and thus to commit that the next
round would be within one year of the first round. Moreover, one of the
justifications made by ICANN for the high costs of the application was
that this is because it is the first round, and the claim was that in
next rounds costs will be lower. Since IDN TLD applications from poor
countries are expected to be submitted once that happens, the time
commitment should be exact.


Section 1.5.1:

(1) As many others have noted either publicly or privately the costs are
clearly excessive and disproportionate regarding the fact the process is
designed to be mainly an online and automatic process, except for the
dispute resolution process which by itself has a separate fee schedule
and therefore is not included in the application costs. Costs estimated
by ICANN for the dispute resolution process which is known to be time
consuming, are in the thousands or lower tens of thousands - costs that
are much more reasonable than the application fees. Moreover - in the
round of year 2000, while ICANN had much lower revenues, staff and
resources, the fee was only $50K and some even refundable.


(2) It seems that ICANN is trying to prevent unnecessary/problematic new
gTLDs by using a basic economic rule of higher costs leads to lower
demand. The problem is that this doesn't take into consideration the
fact that many of the current powerful players in the domain market are
parties that use different methods and manipulations of the domain
market in order to maximize profit (i.e. traffic based registration,
domain tasting and more) while other issues such as expanding the use of
the Internet, the stability of the Internet, protecting the rights of
others, etc. are not in there interests. Thus, cost is clearly not going
to be a barrier for speculators, and the prevention should come from
other provisions within the process.


(3) In any case, it seems reasonable for ICANN not to use the cost
barrier in the case of IDN gTLDs which are expected to have a
significant effect in their contribution to worldwide non-English
speaking communities, and define a lower application fee for new IDN
gTLDs, mainly for those that are coming from developing and poor


(4) While justification for the application fees is questionable the
reasoning for an additional "Registry Services Review Fee" of $50K is
puzzling. This is clearly something that should be folded into the
current application cost, especially if ICANN claims it is going to
occur in rare cases.





Yoav Keren



Domain The Net Technologies Ltd.

81 Sokolov st.      Tel:  +972-3-7600500

Ramat Hasharon   Fax: +972-3-7600505

Israel 47238




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