COMMENTS ON DAG3

["俞阳" <leo@xxxxxxxxxxx>]

To whom it may concern,

Module 2
2.2.1 We suggest ICANN allow those applicants who move forward to the extended 
evaluation process to improve their applications. It is really important to 
non-English speaking communities. Due to different cultures, we shouldn’t 
expect a perfect English application from IDN community. There may exist 
misunderstandings need to be directed by ICANN, there are applications in good 
faith need to be perfected rather than rejected. 
 
2.3.2 and 3.3.4 Shall we re-iterate that for IDN applications, there must be at 
least one (two seem to be perfect) panelists who come from the local community 
on each of the panels.  It will be much efficient and may cost even less.
 
Module 3
3.4.2 To make the new gTLD a long-term project, we still consider the existing 
TLD operators should not be allowed to make a legal rights objection and to 
interpret similarity across IDN scripts by means of meaning similarity. If the 
final DAG makes no change on this, it may easily lead to the blocks of the 
majorities of IDN applications and embarrass ICANN for sure. Base on the 
leading position of ASCII TLDs and their “existing priority”, there will not be 
any competition in IDN gTLD, the war is end before starting. Therefore, we 
sincerely suggest ICANN redefine the scope of “string confusion” and make the 
new gTLD application a true global event.
 
Module 5
We consider the final Registry Agreement must be posted ahead of the opening of 
the new gTLD application period. 
5.2.1 The absolute requirement for DNSSEC will challenge ICANN’s intent of 
geographical diversity, especially in its IDN project.
We all know the failure story of “.xxx”. Will it happen again in this round? No 
one knows. Who can guarantee the winning gTLD will be put into the root? Since 
the JPA was replaced by the AOC in late September, can ICANN put the promise 
into the DAG?
 
Besides, we suggest ICANN open IDN gTLD fast track so as to get the number of 
the potential gTLD, reasonable data for root scaling study and enable the 
communities who are mature in technology, policy and marketing to apply IDN 
gTLD as fast as possible.
Therefore, we strongly support the proposed “Expressions of Interest”. To 
ensure the participation in the EOI accurately represents the level of 
interest, there must be a deposit, which should be refunded if ICANN fails to 
start new gTLD application in the second half of 2010. If ICANN does, the 
deposit should be part of the total application fee of US $ 185,000. 
The information collected from the EOI participants should be the basic 
information of applicants and applied-for strings, as found in Question 1-9, 
13-14 and 18, Evaluation Questions and Criteria, Attachment to Module 2 of DAG.
To protect the interest of the applicants, ICANN need not to make all the 
information public. But ICANN should inform the public the number of the 
received application, number of IDN gTLD among the total application and the 
number of applications in one single language.
All those statistic and applied-for string information should be revealed to 
GAC so that GAC can coordinate with relevant countries and territories.
To those applications that pass the Initial Evaluation but are involved in 
disputes, or applications that are significantly influenced by the changes of 
DAG，the application may be suspended or queues in line. But those applications 
without dispute or applications with disputes that can be solved by mediation 
should start the application process without any delay.
The benefits of EOI outweigh risks. ICANN need to charge proper amount of 
deposit and to keep commercial details confidential.       
Chinese netizens long not only for IDN ccTLD but also some specific category 
domain, some key industries in particular. Therefore, some IDN gTLDs do need to 
be moved forward by means of fast track.
As EOI aims to provide some data and basis for various kinds of studies, we 
suggest the activities start before the ICANN Nairobi meetings. 
Sincerely,

Yang Yu
China Organizational Name Administration Center (CONAC)