The following is our comment\objections on module 3 of the New gTLD Applicant Guidebook Version 3

["Alexei Sozonov" <sozon@xxxxxxxxx>]

The following is our comment\objections on module 3 of the New gTLD Applicant 
Guidebook Version 3:   Module 3 3.1.2.1  There is an absence of strong\precise 
definition of "similarity" in the String similarity Review of Module 2. In case 
if current TLD operator using this uncertain "similarity" definition stop new 
string application, that should be the case for any other applicants, including 
existing TLD operator who initiate objection.   3.3.2Is consolidation of 
objections in a view of reducing\saving cost possible?  3.3.4In case of forming 
the panel in a view of solving IDN applicant question, somebody in that panel 
HAVE to be native speaker representing IDN community was this language is used. 
This is a critical requirement.   3.4.2 Point 1  The meaning similarity. 
Whatever language\script used the meaning\aural similarity (there is an absence 
of strong\precise definition for both in DAG3) for IDN scripts/languages which 
sneakily appears in the last GNSO IDN Expert Working group Report (after it was 
discussed and cleared in String Contention Review) - there is NO cause for 
similarity. Based on this grounds one can see meaning similarity in com\biz 
existing strings. The Legal Rights Objection as an "existing mark" should be 
allowed for parties who has legal grounds to object, but NOT existing gTLD 
operators, since they have own String confusion mechanism for objection and 
principles of # 3.1.2.1. above here should be applied.  In case if an existing 
TLD operator is allowed to make a legal right objection across IDN scripts NOT 
only as "visual similarity" by freely using undefined similarity meaning - as 
meaning, aural etc. - it'll be definitely viewed as "sybersquatting of meaning 
and auras" and will lead to the legal appeals. In any reasonable person test 
"sybersquatting of meaning and auras" is unfair, nonsense and should not be the 
case.Moreover, by applying the same criteria on 500 new ASCII gTLD strings for 
500 new meaning we in danger to face sybersquatting of 500 meanings and auras 
by ASCII applicants which is, again, unfair, nonsense and will be disputed 
definitely. For most of big languages\countries this is nonsense and 
unacceptable deeply  The "existing mark" across IDN scripts should be 
considered for the Legal Rights objection ONLY in case that this mark 
registered in the country were this language\script used and spoken as an 
official language. No trade mark in the country were this language\script used 
and spoken as an official language no grounds for objection.  Very Best 
Regards, Alexei Sozonov CEO Regtime Ltd / Russia / +1.604.773.9204