MarkMonitor - Detailed Comments on Module 3

["Elisa Cooper" <Elisa.Cooper@xxxxxxxxxxxxxxx>]

MarkMonitor is pleased to submit the following detailed comments
regarding Module 3 of the Draft Applicant Guidebook.

Section 3.1.5 - Independent Objector
According to the latest revisions in DAG3, the Independent Objector will
be forced to cover filing and administrative fees, which will only be
refunded in cases where the Independent Objector prevails. However, with
this approach, the Independent Objector is likely to only file
objections when a favorable ruling is certain, and may shy away from
more questionable, yet still important cases. We would recommend that
all filing and administrative fees arising from actions taken by the
Independent Objector be covered by the new gTLD application fee
proceeds. We also believe that the Independent Objector should be
required to conform to the new gTLD Application Program Code of Conduct
to prevent any real and apparent conflicts of interest.