comments and change requests for the 4th Draft Applicant Guidebook on behalf of the dotBayern initiative

["Dr. Markus Bahmann" <m.bahmann@xxxxxxxxx>]

Dear Sirs:

For the 4th Draft Applicant Guidebook we have comments and change requests by 
which we are aiming to get a fair and timely treatment on our way to acquire 
our own identity on the Internet:


RE Timeline / ICANN Summit
**************************
Again we urge ICANN to finalize the gTLD process and start accepting new gTLD 
applications. Any actions which may facilitate this are highly welcome, like 
the proposed "ICANN Summit" in September, in which we would be happy to 
participate!
 

RE 4.2.3 Community Priority Evaluation Criteria
***********************************************
The ccTLDs are geographically and geopolitically based top-level domains which 
are based on the RFC 1591 which states for the administrator of a
ccTLD:

"These administrators are performing a public service on behalf of the Internet 
community."
"The designated manager is the trustee of the top-level domain for both the 
nation, in the case of a country code, and the global Internet community."

We ask that the same is self-evident for applicants for a GeoTLD (incl.
cities, regions, cultural and other geographical and geopolitical strings). 

For this reason we claim:

> One extra point in the Community Priority Evaluation should be given 
> if the organization of a GeoTLD applicant is based on a multi-stakeholder 
> community of the GeoName concerned.

Many of the recently emerged new gTLD applicants may take advantage of the 
immense delay the new gTLD program has been facing since its start in 2005.
The tentative timeline published with the Board's approval of the new gTLD 
program in June 2008 stated an application window for March 2009. We think that 
applicants like us which were planning with this timeline already had a ripe 
application, while a number of new applicants who came in during the last 18 
month seem to rather copy existing concepts and projects or have questionable 
business models. 

For this reason we claim:

> One extra point in the Community Priority Evaluation should be given 
> if organization of an applicant was already established before the approval 
> of the new gTLDs program by the ICANN Board on 26 June 2008 or before the 
> first 
> communicated application window in March 2009.


RE Treatment of incomplete Applications
***************************************
We expect that the provisions in paragraph 1.1.2.8 (String Contention)

". if an application is identified as being part of a contention set, string 
contention resolution procedures will not begin until all applications in the 
contention set have completed all aspects of evaluation, including dispute 
resolution, if applicable."

will be used in competing applications (contention sets) to take speculative 
advantage of intentionally caused delays by incomplete applications.

For this reason we claim:

> Applicants should be given limited time of max. 4 weeks to mend 
> incomplete applications parts.

Thank you very much for taking up our thoughts into the proposed process for 
the introduction of new gTLDs.


Dr. Markus Bahmann
Chairman

Vorstand des dotBayern e.V.
.bayern Top-Level-Domain
Nymphenburger Str. 5
80335 München

Tel.: 089/520313-42
Fax : 089/520313-99

www.dotbayern.de