DOTZON Comments on DAG4

["Katrin Ohlmer | dotBERLIN" <ohlmer@xxxxxxxxxxxx>]

First of all we would like to thank ICANN staff again for their tremendous
work on the new gTLD process. For more than 5 years we participated in this
process, let us now take the last steps in an orderly manner and bring it to
a good ending.

DOTZON consults companies and organizations how to apply for their own
top-level domain (TLD) e.g., .brand, or .company. Our clients include German
industry leaders (DAX 30 stock market index) and Internet companies.

In this capacity we would like to make comments to the fourth draft of the
Applicant Guidebook:

Need of a reliable timeframe
Businesses need reliability when planning to extend their branding on the
Internet with an own TLD, especially for the benefit of secure
communications with their customers. We urge ICANN to expressly state a
reliable date for the application period of the next round. All applicants
writing their business plans are in need of this information, both from a
business and financial planning perspective. Otherwise some, if not many,
applications might not be filed which is contradictory to ICANNs core values
(no 6) of "Introducing and promoting competition in the registration of
domain names where practicable and beneficial in the public interest".

Finalize last open issues in a timely manner
The last open issues need to be solved with necessary accuracy and duly
respect but without delaying the process any further:
- IP Clearinghouse: We encourage ICANN to share first drafts of the IP
clearinghouse process as soon as possible.
- Economic study: There will never be certainty about future extensions of
the domain name space, to cite Yogi Berra: "Prediction is very hard,
especially about the future".
- Morality and public order (MOPO): We encourage ICANN to stay with the
current options already incorporated in the DAG4 and not extend the MOPO
discussion any further. A MOPO black list won't solve problems.

Clear language in Applicant Guidebook
Right now there are several places which give space for interpretations,
e.g. Part 1.1.2.5 'Public Comment': Who will handle public comments in which
way - ICANN staff, the independent evaluators, and how will those public
comments be reflected in the evaluation process? We suggest to lectorate the
writing to eliminate interpretation possibilities. This will keep the whole
application process smooth, potential applicants will gain more reliability,
and claims against ICANN minimized.

No delaying of the process through "bad faith Interventions"
Don't let people interfere just for the sake of interference, there have
been thousands of opportunities to make one's voice heard. Members of the
ICANN community can't say they haven't been heard. Instead 'outsiders'
should get enough time to familiarize with the new gTLD opportunities -
let's start the communication period rather sooner than later.

Keep Trust & Reliability of the Internet
The huge success of the Internet is based on its openness, it is constantly
adoption to users' needs and in most parts of the world elementary for
communication, the exchange of ideas and freedom of expression. Consumers
can rely on its availability, have trust in registrars and registries and
the constant developments to accommodate users' needs. This achievement
should not be risked!

We would like to thank ICANN for the opportunity to comment.

Katrin Ohlmer, CEO, DOTZON GmbH, Berlin, Germany