.GMBH Comments on DAG5

[Andreas Schreiner <as@xxxxxxxxxxxxxxx>]

.GMBH is aiming to create a top-level domain for companies in Austria,
Germany, Liechtenstein, Luxembourg and Switzerland which have the legal form
of a GmbH (comparable corporate form to a LLC or LTD). The new .gmbh
namespace will offer trusted domain names which are verified and will
enhance search engine rankings for GmbHs. Moreover .gmbh will strenghten the
image of the GmbH corporate form Europe wide. The .gmbh project is supported
by companies, associations and political parties.. For the gTLD Applicant
Guidebook (proposed final version) we have comments and change requests:

RE: 1.1.1 Application Submission Period

We have started publically with our project in early 2008, did tremendous
outreach within the community and received significant support for relevant
organizations so far by politics and business organizations. One highlight
was the presentation of .GmbH in Dec 2009 at a well attended new gTLD event
organized by the German Government and leading industry chambers and
associations which also created excellent media coverage.

>>> For the reason of a long lasting and broad discussion on .GmbH we think
a 30-days application window should be more than sufficient, especially if
the next application opportunity arises a year later.

RE: 1.1.2.8 String Contention

During a Community Priority Evaluation ICANN will submit the comments
received during the public comment period to the evaluators with
instructions to take the relevant information into account in reaching their
conclusions. We are concerned that this provision could lead to thousands of
comments on behalf of a particular applicant in order to score higher in a
Community Priority Evaluation or in opposite to impair a particular
application. We ask ICANN to clarify which kind of comments and information
submitted is really relevant and will be considered by the evaluators and
how it will be ensured that the pure quantity of comments will not
necessarily lead to a better scoring.

RE 4.2.3 Community Priority Evaluation Criteria

The Community Priority Evaluation Criteria have been set up by ICANN with
the goal to score community TLDs higher than standard TLDs with regards to
the accountability to the community and the global representation of the
community on the Internet. For instance a long-standing community-based
application for .football that has support of major global football
organizations should be scored higher than an application that has support
only by a national football association or is just a standand gTLD
application. However the current Community Priority Evaluation scoring
system does not fully support this goal. Currently bona fide community-based
applicants for a certain community are not able to get a higher score than
ostensibly “good faith” applicants which are assumed to take advantage of
potential loopholes in the Community Priority Evaluation scoring system.
This affects also long-standing bona fine generic community-based TLDs such
as .eco, .hotel, .music or .gay.

>>> For this reason we claim that for each of the following conditions one
extra point in the Community Priority Evaluation should be given:

- If the applicant’s organization has shown in its application that is based
and supported by a sound multi-stakeholder community of the string concerned
and is accountable to the community. 

- If the applicant’s TLD initiative was already established before the
publication of the first Draft Applicant Guidebook on 24 Oct 2008 which is
evident by the incorporation date of the applicant’s organization or a
publically accessable website or by other equivalent provisions.

- If the applicant’s organization has untertaken fundamental, continuous,
and documented outreach at least during the last 2 years within the
community concerned. This is defined by having spoken-up and/or presented on
relevant conferences, stakeholder groups, ICANN and on other occations as
well as having published about its TLD initiative.
--
Andreas Schreiner
Geschäftsführer

T: +49.89.55061-550

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