Module 5 Comments
5.2.1 ICANN needs to be extermely clear well before application rounds are announced whether applicants must agree to DNSSEC since many countries are reviewing their DNSSEC policy. This is one sure way to reduce the lack of diversity in applicants particularly in IDN TLDs, and probably ensure that even IDN gTLDs and their langauge/scripts end up being run by the typical Western corporations. 5.2.1 Item 5. IVP6 Reachability should be simply be removed now. In the currenet economic climate, almost almost all ISPs in the world, including the USA have no real plans to spend the monies/commit. Given long roll-out schedules and if ICANN wants diversity in applicants, it is unlikley the ISP situation is going to change in any time-frame that anticipates the submission of applications (risk $$$)
in the next 12 or even 24 months.5.2.1 Item 6: Escrow companies should not be limited only to US companies subject to US Patrot Act. Ideally any legitimate escrow company from an applicant's country of origin should be explicitly allowed for at the outset. Otherwise there could be a situation where after spending a small fortune and applicant ultimatetly ends up being caught between ICANN final requirements and local national laws. 5.2.2 The Securing of a suitable financial instrument is expected of a creditworthy instituition. DOes this mean a US or a European one, even if most of these are now insolvent and make local third world banks look like stars ? Can an instrument from a reputable local bank in Ethiopia or a regional one from Bangladesh or a small Vietnamese or even one from Iran suffice ? ICANN needs to make the qualiifications of creditworthiness, taking into light the current financial turmoil, upfront clear so as to avoid unfairness at the end to a winning applicant. If such onerous financial requirements are being insisted upon, the requirement for diversity in applications necessarily entails having to consider and allow for the creditworthiness of diverse and varied local financial instituitions.
5.2.2 Presumably when the Guidebook was originally written in mid-2008, the definition of a creditworthy financial institution meant "US or Western bank" and any local small reputable but globally unheard of bank from a poor country would have been completley unacceptable to ICANN. Possibly these insolvent banks are still "creditworthy". Nevertheless, in the current climate no "global" bank acceptable to ICANN, insolvent as they are, are likley to extend credit to any 'dubious" and risky Western (let alone developing world) venture purporting to launch yet another gTLD and the best any applicant can do is find one who is a lot closer to home. And in the case of applicants from less developed parts of the world, especially with IDN applications, these would be smaller, local unheard of but solvent banks. ICANN needs to make clear what "creditworthiness" means, other than "big global brand name" , before an applicant spends money, wins and then cannot provide a financial instrument from a buzz-word bank. And it has to allow for local in-country banks of local repute or
forego diversity in application.