Here is our comments on module 4 of the New DAG 3

["Alexei Sozonov" <sozonov@xxxxxxxxxxx>]

Module 4 

4.1.3  The highly possible likelihood of self-resolution of a string contention 
by re-crafting the application 
as a joint venture is NOT-accepted solution in current draft. ICANN's rejecting 
to accept this a solution 
as that there will be sufficient material\documentation change and new costs 
will be involved. 
So, at least 2 or more parties will loose $185K each, and file completely new 
round. 
The cost of such solution seems to be NON-adequate from any reasonable person 
view. 
It'll be good if for such cases new and fare cost-reflective policy will be 
crafted by ICANN. 
The possible cost of ICANN's savings in case of self-resolution of two\more 
fighting parties 
seems to be fare to consider as well. 
4.2. Criterion 4 :
In the community evaluation process any applicant might be blown of a point by 
single opposition. 
Particular standard applicant highly probable might want the community 
evaluation to fail and 
could use this as a tool to appose any community applicant. 
Thus it might lead to the point that the community evaluation process became 
mostly meaningless. 
There is a possibility for any existing TLD operators to file a community 
objection and it would be 
viewed as a sufficient. Seems to be obvious that in any comparative evaluation 
existing TLD 
operators to be excluded from opposing.
4.3.2.  The exact Registry Agreement needed to be published prior to the 
beginning for the application 
period or payment of application fees. This agreement must guarantee in the 
beginning, that the 
applicant starting the process, all the criteria of eligibility for granting 
the delegation according to 
the Registry Agreement, ICANN Board and US Department of Commerce (IANA) 
approval of the TLD.
 
Very Best Regards,
 
Alexei Sozonov
 
CEO Regtime Ltd / Russia / +1.604.773.9204