Module 1 comments

["S. Subbiah" <subbiah@xxxxxxxxx>]

1.1.5 ICANN has said the high application fees are for first round. 
Later rounds will be far cheaper when
poorer IDN applicants presumably can apply. ICANN has a goal but does 
not in writing commit/promise
that the next round will open a year later.

1.5.1 (i) The application fees are way too high for a largely automated 
online process, with key additional parts outsourced
to others with seperate costs. The costs to object are far less than to 
apply and sets up an unfair balance.
The outsourced dispute costs seem more reasonable when comparing the 
work ICANN will be carrying
out and what the dispute providers may have to do.
(ii) Despite ICANN's view otherwise, there should be no seperate 
addtional Registry Services review Fee of $50 000,
particularly since ICANN seems sure that it will happen only very rarely.
(iii) As observed before, unless the high costs ar ereduced by an order 
of magnitude, ICANN will not see its stated
goal of diverse applicants from anywhere but the standard few 
Western/rich countrie, particularly for IDN TLDs. Despite
suggestiosn for almost 2 years, that ICANN has sufficinet 
reserves/revenue to upfront part of the fees (possibly
according to relative GDP) and cost-recover from winning applicants' 
future opertaions ICANN refuses to consider this while
at the same time apparently losing millions on the stock market. It is 
to be noted that GAC a year or so ago expicitly
asked ICANN to have more diversity in its registry applicants.