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.berlin Comments to DAG3

  • To: <3gtld-guide@xxxxxxxxx>
  • Subject: .berlin Comments to DAG3
  • From: "Dirk Krischenowski | dotBERLIN" <krischenowski@xxxxxxxxxxxx>
  • Date: Sun, 15 Nov 2009 15:55:17 +0100

With our .berlin TLD project we participated in and contributed to the new
gTLD process from the very beginning in 2005. With our partners and
community, we represent thousands of Berlin based SMEs, organizations that
are owned or shared by the City of Berlin, hotels, Internet businesses,
registrars and individuals. For the 3rd Draft Applicant Guidebook we have
comments and change requests by which we are aiming to get a fair and timely
treatment on our way to acquire our own identity on the Internet.

Capital Names need to be protected
Capital Names like BERLIN or PARIS have been noted as separate sub-category
of Geographic Names in DAG3; this is a step forward to their protection. As
we and others understand DAG3 it is still possible to file an application
for .berlin if the applicant is the Town of Berlin (Vermont) with a support
letter of the US Government. This is not acceptable for Capital Cities.

Creating Competition do not mean Lower Prices for Domains
Price competition is not necessarily associated with lower domain prices; it
is also a question of the added value a new domain name offers. If a Berlin
based sunflower shop can reach a better search engine position with a US$
50.00 www.sunflower.berlin than with a US$ 20.00 www.sunflower-online.net
then the initially more expensive .berlin domain name offers huge cost
saving at the end of the day. 

There is a clear Demand for GeoTLDs
City and Geo TLDs are always mixed up with other new gTLDs in the discussion
on economic parameters. First of all the studies the German Internet
Association eco and separately we as dotBERLIN have conducted show that e.g.
80% of businesses would be interested to register a .berlin domain name and
43% of individuals prefer www.mayor.berlin as their preferred domain name to
find the Berlin mayor. Secondly we do not see any economic consultant or
ICANN in the position to decide if a city or geographic region has a demand
for its own identity. It should just simply be mentioned in the upcoming
economic studies that there is a significant demand of cities, cultural,
linguistic and geographic regions for their own TLD.

New gTLD Applicants need a Timeline!
We urge ICANN to proceed with the introduction of new gTLDs. Arguments on
this topic have been articulated on plenty occasions by new gTLD prospects
and other members of the ICANN community, we do not want to repeat them

Dirk Krischenowski
Founder and CEO
dotBERLIN GmbH & Co. KG
Akazienstrasse 2
10823 Berlin
Tel +49 30 49782354
Fax +49 30 49782356
Mobile +49 173 2339156
E-Mail krischenowski@xxxxxxxxxxxx
Skype "krischenowski"
Web www.dotberlin.com

Attachment: Comment_dotBERLIN_DAG3_2009-11-14.pdf
Description: Adobe PDF document

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