Comments by HOTEL Top-Level-Domain GmbH on the 3rd Draft Applicant Guidebook

[Johannes Lenz-Hawliczek <johannes@xxxxxxxxxxx>]

Comments by HOTEL Top-Level-Domain GmbH on the 3rd Draft Applicant
Guidebook

Let me first thank the ICANN community and ICANN staff for the
productive debates and the tremendous amount of work that has been
done over the past five years to come up with such a well balanced
proposal.

I would like to add a few comments with regards to the time frame and
to the remaining open issues.


Deliver a reliable time frame

Everybody needs reliability when planning for the future. Hotel
associations, chains and individual hotels wolrdwide are looking
forward to having their own namespace. We urge ICANN to commit to a
reliable date for the application period of the next round as soon as
possible.

Trademark Protection

Hotel Top-Level-Domain GmbH views the protection of rights as a very
important issue which we adress in our policies. We are currently
creating an advisory board of experienced and representative members
of the global hotel industry to ensure that the needs of the hotel
community are adequately adressed in our business concept. Since the
GNSO is actively working on its recommendations to the ICANN board
regarding the proposed rights protection mechanisms we firmly believe
that consensus on this subject can be reached shortly.

Economic Impact

We operate with the support of the International Hotel & Restaurant
Association (IH&RA) which represents 300.000 hotels worldwide, and a
number of other national hotel associations and individual hotel
chains and hotels. There is a clearly stated demand from this industry
for new and intuitive domain names within the .hotel namespace.

We do not support the argument that new gTLDs will automatically lead
to lower prices for domain registrations. 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 hotel achieves
better search engine rankings with a US$ 50.00 www.whatever.hotel than
with a US$ 20.00 www.whatever-hotel.net then the more expensive .hotel
domain name offers huge cost savings at the bottom line.

Root Scaling

Many members of the technical community at ICANN have stated that one
hundred new TLDs per year should cause no problem, even if DNSSEC is
deployed in parallel. Assuming that the application window opens in
2010, and applications are processed during 2010, 2011 and even in
2012, there should be no problem with adding some new TLDs in 2011,
some in 2012 and some in 2013 respectively.

Sincerely

Johannes Lenz-Hawliczek
CEO

HOTEL Top-Level-Domain GmbH, Berlin, Germany

November 2009