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SIDN's comment on draft Application Guidebook v3
- To: <3gtld-guide@xxxxxxxxx>
- Subject: SIDN's comment on draft Application Guidebook v3
- From: "Roelof Meijer" <Roelof.Meijer@xxxxxxx>
- Date: Mon, 23 Nov 2009 09:26:22 +0100
On behalf of Roelof Meijer, I herewith send you SIDN's comment on draft
Application Guidebook v3.
Kind regards,
Natasja Leushuis
Secretary to CEO
1. Vertical separation between registries and registrars
SIDN's position on this matter is that ICANN needs clear rules, based on
bottom-up developed policies for the issue of separation or (partial)
integration of registries (and back and providers) and registrars (incl.
resellers). Therefore we would like ICANN to clarify the current policy and
rules and how they could be used for the new gTLD process. We understand from
the the current debate on registry-registrar separation that there might well
be reasons to modify those policies and rules. Some argue for stricter rules,
others for more freedom. In our opinion, however, this is a complicated issue
that cannot be solved overnight. Therefore it is SIDN's position that any
changes in the existing registry-registrar separation policies need to be
developed using the Policy Development Process. Due to the fact that such a
process takes considerably time and thus would significantly (further) delay
the new gTLD process, it is out opinion that it should be a parallel track to
the new gTLD program and not an overarching issue that needs to be solved
before new gTLD's are implemented.
2. Root scaling study
SIDN supports the methods and the conclusions of the root scaling study
report. We agree with the authors that the provisioning chain of the root
system does not allow for large or fast increases in the root zone file and
therefore we agree with the conclusions of the report that a combined
introduction of IPv6, DNSSEC, IDN ccTLD's and gTLD's is not a good idea. It is
now up to ICANN to provide the community with a proposal and a roadmap on how
to deal with this issue and how to prioritize the implementation of these four
changes in the root. Furthermore ICANN needs to show the community a solution,
or a roadmap to such a solution, for the provisioning problem if there will be
no boundaries for the number of new gTLD's per round or the total number of
gTLD's in the root. If ICANN, however, wants to design these boundaries they
will have to be designed in a Policy Development Process, since there is
clearly no policy at this moment for implementing such boundaries.
3. Demand for new gTLD's
SIDN considers the study for the fundamental demand for new gTLD's to be
important. ICANN needs to do more research on this issue, but this research
should be (internet domain) market research based on facts and should focus on
demand of potential new applicants and internet users and should not have the
theoretical approach of the previous studies. ICANN furthermore should present
the benefits of the new gTLD's, resulting from the demand, vis-à-vis the
possible drawbacks and the potential costs associated with these drawbacks.
4. Proposed EOI mechanism for new gTLD's
The discussion on many issues still unresolved, including the three issues
mentioned above, will merit from a clearer picture of how many and what kind of
proposals supported by whom can be expected in the first round. Therefore SIDN
supports a EOI mechanism as proposed in the public forum in Seoul. Such a EOI
should consists of the possibility to express ones interest in a particular
TLD, supported by the objectives, target group and the underlying business
model. The results of this EOI should be public and therefore only those who
presented their interest should be enabled to participate in the subsequent
first round of applications. The fee for the EOI should be significant (but
deductible from the application fee) in order to prevent frivolous
applications. We suggest an amount of $55.000,- which equals the costs of
withdrawing an application after the initial evaluation has taken place. The
EOI should in our opinion not lead to a "fast track" handling of the presently
unsolved issues. The evaluation should only start as soon as all outstanding
issues are resolved which guarantees that there will not only be one round now
and no other rounds in the foreseeable future.
5. Trademark issues
We generally support the way staff has worked out the IRT proposals. We
however feel that a sunrise or other pre launch rights protection mechanism
should be mandatory for all TLD's offering domain names to the public. The
same applies to the URS.
With regard to the URS we do not see why the remedy has to be different from
the UDRP. We assume that as soon as the registration period of a URS suspended
domain ends, it will be caught by another registrant with the same intentions
as the previous holder or will be renewed (the rules do not mention if this is
allowed) by the current registrant and then the URS will start again. In the
case of a transfer to the rights owner, it will be up to that party to decide
to run such risk and cancel the domain or keep it registered to avoid further
trouble. If the current proposed remedy remains in place, we suggest that in
default cases a registrant (after paying a fee) will be allowed to reopen the
URS-procedure at any time during the suspension and so avoid the 'I have not
been duly informed' discussion.
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