RE: Comment regarding Market Differentiation

["Ron Andruff" <randruff@xxxxxxxxxxxxxxx>]

RE: Market Differentiation

 

Our DAGv3 comments
(http://forum.icann.org/lists/3gtld-evaluation/msg00002.html) on the topic
of market differentiation pointed out that the GNSO Final Report of the
Introduction of New gTLDs calls on ICANN to "facilitate the introduction of
new gTLDs in an orderly way, as well as introducing new gTLDs to include
market differentiation."  
 
We take note that ICANN staff has taken steps to address the GNSO's call -
and that of the community at large - for market differentiation.  In
question #18 (Module 1, 1.4.1.1), as detailed in the section on the
information collected in the user registration process, the Applicant
Guidebook now asks "Mission/purpose of the TLD".  What potential applicants
do not know is what the evaluators will be looking for in the answer to that
question; neither how it will be reviewed and/or scored in the evaluation,
so it leaves many wondering what purpose does that question serve? In our
view, the staff has not gone far enough with this reference question.
 

The Business Constituency (BC) made a recommendation in its DAGv3 comments
that ICANN should include two questions in the final AG: 

 

   (1) Which users/registrants/organization/group/community do you intend to
serve?

 

   (2) How does your TLD differentiate itself from others in the DNS?  

 

The BC was clear in its statement that "leaving this serious omission
uncorrected at the start of this new gTLD process i.e., approving applicants
irrespective of knowledge that they overlap or undercut other registries, is
antithetical to the first principle guiding the new gTLD policy development
process, that being that new gTLDs will benefit registrant choice and
competition."  

 

In addition, the case for market differentiation, fully supported by the
latest economic study (An Economic Framework for the Analysis of the
Expansion of Generic Top-Level Domain Names by Michael L. Katz, Gregory L.
Rosston and Theresa Sullivan), cautions that ICANN establish clear and
unique names to avoid user confusion.  ICANN must ask applicants how their
new TLD will differentiate itself from any and all others currently in the
root, specifically ensuring that new entrants cannot attempt to partially
serve already served existing communities. Adding this question would ensure
that ICANN establishes an intuitive, non-duplicative DNS to build on in the
coming 10-years as we move from 20 to 200 and more, gTLDs. The study clearly
highlights the havoc and chaos that an "open marketplace" - devoid of
differentiation - would bring to the Internet.  

 

We are asking ICANN to further amplify question #18, to ensure that each
applicant can demonstrate how each new gTLD will differentiate itself from
all others within the DNS.  Quoting the BC DAGv3 comment: "It is only with
sharper criteria. that ICANN can approve those TLDs that valuably expand the
name space and strengthen diversity on the Internet pursuant [to fulfilling]
the terms of the Affirmation of Commitments." 

  
Without market differentiation there will be a high risk that defensive
registrations will become standard practice as opposed to ending the
predatory practice of forcing involuntary defensive registrations in
multiple domain name spaces; something that the ICANN community has worked
hard to bring to an end.
 
Respectfully submitted,
 
Ron Andruff
 
RNA Partners, Inc.
 
Disclosure: RNA Partners intends to be an applicant for a new gTLD.