Comments by Association UNINET

[Iliya Bazlyankov <iliya.bazlyankov@xxxxxxxxx>]

Association UNINET represents three of the biggest domain registration
and web hosting companies in Bulgaria, as well as Internet providers
and IT companies.

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Here are our comments on the Version 3 of New gTLD Applicant Guidebook .

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Module 5

5.0 We suggest that no application fee of any kind should be charged
by ICANN until a final agreement with the prospective gTLD registry is
made available.

5.2.1 The absolute requirement to sign the zone with DNSSEC should be
avoided, because it will be a challenge for the geographical diversity
(especially in IDN applications). For all IDN and geographic
applications (.sofia for example), a local mayoral or governmental
support will be needed, and the requirement for DNSSEC could cause
trouble getting it, because some countries do not like that DNSSEC
will be under a US-operated trust anchor, subject to the US Partiot
Act.

The same applies for the escrow requirement. ICANN should be more
explicit about the escrow company requirements, as this could cause
trouble for the applicant, even if everything else in his application
is great.

Finally, there should be a complete guarantee at the time of
application start, that the US Department of Commerce will insert in
the root all successfully evaluated and winning gTLDs.

5.2.2. The IPv6 protocol is not being widely adopted, yet. The
requirement for actual network tests to demonstrate live
implementation could cause troubles for an applicants from smaller
countries, as they may be unable to find a single IPv6 offering
provider in their country. This cause is even true in some European
countries like Bulgaria, where about 50% of the datacenters are unable
to offer IPv6 connectivity, and the others are only IPv6 ready. So you
must go and find your own IPv6 block before setting up your servers.

We suggest that ICANN should only ask for the software ability to handle IPv6.

5.4. We propose that ICANN should publish what it will do with all the
money that will collect from new gTLD and IDN ccTLD applications. We
estimate that ICANN revenue would be approaching US$200M from the
current $50M.

Module 6:

6.3. This clause says that an applicant could spend millions of
dollars and wait many years, and finally do not get his gTLD. Even in
points 6.5 and 6.6, we can see that when an applicant is refused to
get his gTLD, ICANN will keep his money and he have no right to
complain or sue them.

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Kind regards,
Iliya Bazlyankov
Chairman of Association Uninet

http://www.uninet.bg
iliya.bazlyankov@xxxxxxxxx