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Comments on Module 5

  • To: <3gtld-transition@xxxxxxxxx>
  • Subject: Comments on Module 5
  • From: "Yoav Keren" <yoav@xxxxxxxx>
  • Date: Mon, 23 Nov 2009 01:31:24 +0200

The following are my comments on module 5 of the New gTLD Applicant
Guidebook Version 3:


5.1 This paragraph refers to a "draft registry agreement" that "does not
constitute a formal position by ICANN". ICANN must present before the
launch of the new gTLDs RFP the final agreement that new gTLD registries
will be committed to sign. Since ICANN is about to charge a
non-refundable application fee of $185K, it is essential that ICANN will
allow potential applicants to review the complete obligations they will
be bound in before they apply and pay the application fee.


5.2.1 ICANN should provide specifications regarding the requirements for
an Escrow agent. 
The western standards for Escrow agents are much different than those in
many countries, especially non-western ones, some of which potential IDN
gTLDs applications may come from. If ICANN's requirement is for a
US/Western Escrow agent it might be illegal for some applicants (such as
IDN gTLD applicants from non-western countries) to escrow the data with
a US/Western agent. Thus ICANN should take these constraints into
consideration in its requirements for an Escrow agent. It is also
important the requirements are set before the new gTLDs process is
launched so that applicants will not find themselves spending hundreds
of thousands of dollars and then unable to meet the escrow requirements

Additionally, the guidebook should be very clear whether implementing
DNSSEC is going to be a requirement to run a new gTLD registry. ICANN
must take into consideration that applicants from different countries
may be caught in the middle between an ICANN requirement for DNSSEC and
a local government that objects to DNSSEC implementation. Thus, if this
issue is not clarified in the guidebook applicant may find themselves in
a problematic local legal situation long after they have spent
significant funds in the application process. 


5.2.2 IPv6 Support - IPv6 implementation is still rare around the world,
and especially outside of the US. Finding an IPv6 ISP and co-location
hosting center outside of the US will be very hard in the near future
(especially with the current world economic situation), and will create
an obstacle mainly for IDN applicants. To ensure the diversity of
applicants and new gTLD registries this requirement should be removed.






Yoav Keren





Domain The Net Technologies Ltd.


81 Sokolov st.




Ramat Hasharon




Israel 47238





























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