DOTZON Comment to DAG3

["Katrin Ohlmer" <katrin@xxxxxxxxxx>]

First of all we would like to thank ICANN Staff for their patience, support
and enthusiasm with this process, its stakeholders and opponents. For more
than five years we participated in the new gTLD process, walking all in the
same direction. Let us now take the last steps in an orderly manner and
bring this process to a good ending. 

DOTZON consults companies and organizations how to apply for their own
top-level domain (TLD) e.g., .brand, or .company. Our clients include German
industry leaders (DAX 30 stock market index) and Internet companies. For
competitive reasons these companies won't show up at ICANN and tell ICANN
that they are planning to apply for a TLD. At the same time, those who are
opposed to new TLDs make their voice heard very clearly. This is an
unbalance that has to be taken into account. 

In this capacity we would like to make comments to the third draft of the
Applicant Guidebook:

Work on reliable Timeframe
Businesses need reliability when planning to extend their branding on the
Internet with an own TLD, especially for the benefit of secure
communications with their customers. Many companies in Germany are
evaluating this opportunity. We urge ICANN to expressly state a reliable
date for the application period of the next round. All applicants writing
their business plans are in need of this information, both from a business
and financial planning perspective. Otherwise some, if not many,
applications might not be filed which is contradictory to ICANNs core values
(no 6) of "Introducing and promoting competition in the registration of
domain names where practicable and beneficial in the public interest".
 
Finalize 3 Overaching Issues
There are three last issues which have to be solved. From our perspective
we're close to the finishing line:
1.      Trademark Protection: The GNSO will come up with a recommendation to
the ICANN board until December 9th. After a comment period it should be
possible to reach a consensus in early 2010.
2.      Economic Impact: We did some research about the economic impact of
introducing a new TLD for the dotBERLIN project and are happy to forward a
copy to ICANN staff, as this might help to give an indication of economic
demand in Germany.
3.      Root Scaling: As far as most members of the technical community at
ICANN state, hundred new TLDs per year should cause no problem, with DNSSEC
deployed in parallel. Assuming that the application window opens in 2010,
and applications are processed during 2010, and 2011, there should be no
problem with adding hundred TLDs in 2011, hundred in 2012 and another
hundred in 2013 and so on.

Keep Trust & Reliability of the Internet
The huge success of the Internet is based on its openness, its constantly
adoption to users' needs. In most parts of the world it is elementary for
communicatition, the exchange of ideas and freedom of expression. Consumers
can rely on its availability, have trust in registrars and registries and
the constant developments to accommodate users' needs. This achievement
should not be risked!

Katrin Ohlmer, CEO, DOTZON GmbH, Berlin, Germany

November 2009