Module 5 Comments

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

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.