.bayern Comments to DAG3

["Adina Reichardt" <a.reichardt@xxxxxxxxxxxxxxx>]

Dear Sirs:

Our non-for-profit, charitable and open association dotBayern® e.V. has
invented the proposal and concept for a .bayern® top-level domain already in
2006. The .bayern TLD is intended to server the Bavarian community including
individuals, organizations and the Federal State of Bavaria by its own
identity on the Internet. We are supported by Bavarian individuals and
organizations and are in talks with the Bavarian and German government in
order to support our initiative. For the 3rd Draft Applicant Guidebook
(DAG3) we would like to submit the following comments:

Geo Names need to be protected
******************************
Even if have been noted as separate category in DAG3 worldwide known
geographic names like BAYERN or BAVARIA are in need for a stronger
protection against copycats. As we understand DAG3 it is still possible to
file an application for .bayern if the applicant is a company somewhere.
This is not acceptable.

Please reduce the Evaluation Fees and Annual Fees
*************************************************
The economic perspective of the .bayern top-level domain is likely
comparable to a ccTLD which has a similar sized community. In comparison to
the low entrance fees for ccTLDs to the DNS by delegation the economic
burden for small GeoTLDs with US$ 185,000 evaluation fees and at least US$
25,000 annual fees is far too high.

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
Bavarian based pretzel shop can reach a better search engine position with a
US$ 50.00 www.brezel.bayern than with a US$ 20.00 www.brezel-online.net then
the initially more expensive .bayern domain name offers huge cost saving at
the end of the day. 

There is a clear Demand for GeoTLDs
***********************************
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 has conducted show that e.g. 80% of businesses would be
interested to register a .bayern domain name. Secondly we do not see any
economic consultant or ICANN in the position to decide if the Federal State
of Bavaria should have 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
here.


Adina Reichardt
Co-Chair of .bayern

dotBayern e.V.
Nymphenburger Str. 5
80335 München
Tel +49 89 5203 1342
Fax +49 89 5203 1399
bahmann@xxxxxxxxxxxx
www.dotbayern.de / www.punktbayern.de / www.bayerndomain.org 

Vorstand: Rechtsanwalt Dr. Markus Bahmann (Vorsitz) und RA Adina Reichardt

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