comments 3rd Draft Applicant Guidebook

["Sven Lubek" <sven.lubek@xxxxxxxx>]

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
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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  <http://www.sunflower.berlin> www.sunflower.berlin than with a US$
20.00  <http://www.sunflower-online.net> 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  <http://www.mayor.berlin> 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
here.
Best Regards
Sven Lubek / Covus GmbH & Co.KG
Sven Lubek
Geschäftsführer 
Covus GmbH & Co.KG
Lottumstr. 9-10
10119 Berlin 
Fon:  030-440 136 3
Fax:  030-440 136 50
 
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Persönlich haftende Gesellschafterin der KG: Covus Investment GmbH
Vertretungsberechtigter Geschäftsführer: Dipl. Kfm. Sven Lubek
Registergericht / Nr.: Amtsgericht Berlin Charlottenburg / HRA 35960B