Respectfully Requesting An Extension of the Comment Deadline

[Phil Corwin <pcorwin@xxxxxxxxxxxxxxxxxx>]

The domain name registrants, investors and developers represented by the 
Internet Commerce Association (ICA) wish to respectfully request that ICANN 
extend the comment period on the proposed Final gTLD Applicant  Guidebook (AG) 
by a minimum of two weeks (14 days) and preferably by an additional three weeks.



The 28 days allowed for comment on this AG is just over half the average time 
(50 days) allotted for comment on the four prior iterations of the Guidebook; a 
2-3 week extension would bring the length of the comment period in line with 
that provided for prior versions. This fifth version of the AG does not just 
contain proposed resolutions of previously discussed matters but significant 
new material that we are working to assimilate and understand. Many ICA members 
are present in Cartagena and busy attending sessions and interfacing with staff 
in this attempt, but meaningful participation at the Cartagena meetings 
mitigates against preparation of a fully informed comment letter for 
consideration by our membership prior to its submission in just under four days.



The reasonable extension we are requesting should in no way interfere with 
approval of a Final AG by the ICANN Board that permits opening of the 
application window for new gTLDs in Spring 2011. We certainly hope that the 
December 10th comment deadline has not been set in order to facilitate such a 
vote by the Board in Cartagena. The current comment deadline will occur just 
hours before the start of the Board Meeting in Columbia, and given the time and 
work burdens placed on key ICANN staff by this meeting there is no way they can 
review and meaningfully summarize suggestions and concerns expressed in the 
final round of comments (most of which are usually submitted within the final 
24 hours of any comment period) to aid the Board in understanding them prior to 
a final vote. Given recent expressions of concern by the GAC and individual 
national governments regarding ICANN's policy process, and particularly the 
adequacy of explanations of policy decisions, it is particularly important that 
the Board vote on the Final AG be conducted in a manner that demonstrates that 
all submitted comments have been accorded serious consideration.



We appreciate your consideration of our suggestion on this matter.



Sincerely,

Philip S. Corwin

Counsel

Internet Commerce Association



Philip S. Corwin
Partner
Butera & Andrews
1301 Pennsylvania Ave., NW
Suite 500
Washington, DC 20004

202-347-6875 (office)

202-347-6876 (fax)

202-255-6172 (cell)

"Luck is the residue of design." -- Branch Rickey