AusRegistry International Public Comments - Draft Applicant Guidebook v4

[Tony Kirsch <tony@xxxxxxxxxxxxxxx>]

AusRegistry International wishes to take this opportunity to thank both ICANN 
staff and the Board for their efforts in progressing this program forward.

We respectfully submit the following comments for your review and look forward 
the prompt resolution of the Final Applicant Guidebook and the creation of new 
gTLDs for the benefit of the wider community.



Comment #1

AusRegistry International seeks clarification with respect to the term 
'registry services' as referenced throughout the Draft Applicant Guidebook 
(v4). There are various references to 'registry services' (in lower case) as 
well as 'Registry Services' (in upper case) where we believe the intention of 
the latter is to create a specific definition to the list of 'Registry 
Services' outlined at Question 23 of the Evaluation Criteria within the 
guidebook, and within http://www.icann.org/en/registries/rsep/.



However it is not clear if 'registry services' (in lower case) assumes the same 
meaning.



AusRegistry International requests that ICANN address this area of confusion 
given there are some sections where this may be interpreted in a manner which 
may not be ICANN's actual intent - for example, Module 1 - Restrictions on 
Registrar Cross -Ownership, Point 3 (page 1-18)



'Further, applications where the applicant has engaged an ICANN-accredited 
registrar, reseller, or any other form of distributor or any of their 
Affiliates (or any person or entity acting on their behalf) to provide any 
registry services for the TLD will not be approved.'





Comment #2

With respect to the application process, AusRegistry International seeks 
assurance from the ICANN Board that, once applications have been submitted to 
ICANN, it is the Board's role to simply ensure that applications meet the 
criteria outlined in the Final Applicant Guidebook as approved by the Board. 
Once an application is deemed to have met the set criteria it is not the 
Board's role to make further deliberations about the application's validity or 
eligibility and we request that clarifying language to this effect is provided 
in the Final Applicant Guidebook.





Comment #3

It is AusRegistry International's opinion that, regarding certainty of process, 
every successful gTLD applicant should be provided with a clear indication of 
when their delegation will occur. It is not clear to AusRegistry International 
how ICANN decides the order of delegation and how and when successful 
applicants are informed. We therefore request that clarifying information is 
provided in the Final Applicant Guidebook due to the significant importance of 
this topic to applicants.







Our sincere thanks once again to ICANN Staff and the Board for your continued 
hard work and careful review of the above comments.



Tony Kirsch
Senior Manager - International Business Development
AusRegistry International Pty Ltd