Comments on "New gTLD Applicant Guidebook Version 3"
Following the ICANN announcement at http://www.icann.org/en/topics/new-gtlds/comments-3-en.htm please find below my comments. I've specifically commented on module 5 and my comments are archived at http://forum.icann.org/lists/3gtld-transition/msg00005.html I will here only comment on the generic procedure for new gTLDs. The previous round of new gTLDs was presented as a testbed. This would have implied there are some tests to be made and some conclusions to be reached. As none of this was planned before starting new TLDs at the end of the day the new TLDs do not test anything, they are just new services for the public, with success or not depending on who you ask and on what metrics do you count. I'm not overly enthousiast on all new gTLDs as currently announced in various media, but as the same time I believe that competition should be possible, and that people should be able to innovate and test new services. I do hope that some new innovative ideas are currently lurking in the dark and that they will later on blossom to fruitful new gTLDs as soon as the process is ready. That would make me think that lower barriers of entry are better, as well as reduced timeframes, but without hurry either because after a 10 years delay, 6 months more is not a big deal, and the Internet will continue to function and people to register domain names in current TLDs even if the new gTLDs are not launched tomorrow. I doubt that all these new gTLDs will be able to compete against the current ones that will still exist, but all new gTLDs will compete against one another, that is for sure. Among all cases, there are discussions on 'brandTLD', 'geoTLD' and 'communityTLD', where a 'standardTLD' should probably capture all other cases. All these TLDs should be to the benefit of the whole Internet community and be able to provide new features and values to the day to day life of Internet users. For that, it is often given as example that the new gTLDs will provide easier access to content for users, like someone searching for a pizza in new york will (should) immediately (?) find something worthwile by going to the website at pizza.nyc Now, I fail to see how things would be easier than today when, besides .nyc, some other parties also decide to create .pizza, .food , .restaurant or even .manhattan : now where should the content be searched ? At pizza.nyc ? or nyc.pizza ? or nyc-pizza.food ? or pizza-nyc.manhattan ? etc... Of course it is not for me to judge the merit of all of these, as I said previously the competition should be open, and all Internet users will decide at the end of the day what they prefer, hoping that during that course true innovations may happen. As for geographical needs of TLD, I would note that there was at least one prior instance of that, namely .US (before its redelegation to Neustar) with its 3rd and 4th level of domain names, to take into accounts the US state and locality. The whole scheme has been scraped in favor of a .US running now like any other TLDs, maybe because non-2nd level domain names proved to be difficult to grasp to the public, that may find a geography encoded directly at the top level to be more attractive. Again, the competition should be open, and the players free to test what they want in that aspect. And for the "communityTLD" case since it seems very hard to be able to define what a "community" is in this specific context, and how it should participate in choosing a registry and voicing its support or its disagreement, so I fear that more cases like .XXX will happen in the future, where there are many voices claming to be the community served by it, but without all voices saying the same thing. Maybe the whole notion of "communityTLD" should be scraped. I would however even more be worried about new TLDs started where basically no registration can take place (very small/closed community and brandTLDs), or no use is made at all. This would be a kind of "defensive registration" at the DNS apex, which would then become a tree with dead leafs. I would think that this case of TLD do not provide any benefit to the Internet at whole, and hence measures should be taken so that this case is limited as much as possible. This does not mean that future registry operators should be required to have some minimum number of domain names, just that the TLD is used in practice because the creation of the TLD has been done so that registrations are expected to happen in it, and not just to "reserve" the TLD and lock other players out of it. And I'm not talking about TLDs where the volume of domain names fall during the years or such other cases, but only on TLDs created for the specific purpose of not being used at all. Otherwise a lot of time and energy would have been spent by various actors, besides obviously the registry operator itself, but also many other Internet actors, without any clear benefit to anyone. On a more procedural level, I do note that if the plan is, in the future, to have gTLDs creation on a rolling basis while the first round would be only during a limited timeframe, there are some points in the current guidebook that will be problematic such as string contentions issues and ways to resolve it, as using time and artificially delay or hurry things would change the fate on some issues. More guarantees should also be given upfront about the timelines and level of public data that will be available regarding applications received and their reviews at various stages. Of course, post round, a full assessment would need to be made on the efficiency of the whole procedure as well as the costs involved and the adequacies of fees asked by ICANN to applicants. If these fees change in the future (for future rounds), specifically if they are lowered or if some new cases are described to provide reductions for some specific cases, some first round applicants may feel to have paid more than necessary. Finally, adding many new gTLDs (on the order of hundreds per year) may have various consequences, some already being studied such as higher strain (or not) on the DNS root server and such, but it will have also operational consequences on dealing with registrars accreditation/deaccreditation and listing on ICANN website, registries requests on new services (RSTEP), IANA work and rate of changes such as top level nameservers, amount of correspondence and legal issues to take into account, etc. -- Patrick Mevzek Dot and Co <http://www.dotandco.com/> <http://www.dotandco.net/> <http://www.dotandco.net/ressources/icann_registrars/prices> <http://icann-registrars-life.dotandco.net/>