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Comments on the new TLD Program and the Applicant Guidebook

  • To: "5gtld-guide@xxxxxxxxx" <5gtld-guide@xxxxxxxxx>
  • Subject: Comments on the new TLD Program and the Applicant Guidebook
  • From: Søren Ingemann Larsen <SL@xxxxxxxxxxxx>
  • Date: Wed, 12 Jan 2011 13:52:37 +0100

Thank you for the opportunity to provide comments on the New Generic Top-Level 
Domains (gTLDs) Proposed Final Applicant Guidebook (the Guidebook).

Our colleagues in the company Lego have thoroughly gone through the revised 
Applicant Guidebook, and we fully support the comments given by Mette M. 
Andersen from Lego (see attached) posted on 11 January 2011, see 

As will be seen from this document, it is clear that the ICANN group 
responsible for the proposed new TLD program does not seem to take seriously 
into account the concerns - thoroughly documented, motivated and explained - 
expressed during the past many months from the numerous companies and persons 
interested in a well functioning internet which at the same time provides 
legitimate protection for trademark rights.

It is apparent that the opportunity given by ICANN for public comments is in 
reality a fake one. ICANN has no obligation to take these comments into serious 
account, and ICANN therefore does not. This only confirms what would be the 
only logical assumption in a commercial world namely that the only thing that 
drives this new proposed program is MONEY and not a sincere concern for the 
optimum functionality of the internet.

The entities that have economic interests in the realisation of this extremely 
costly program are ICANN and the Registrants. The problem with the Registrants 
is that they have a double role in relation the companies and other entities 
that might contemplate buying a tld in the proposed Program. They are at the 
same time advisors and sellers. - No wonder therefore that the Registrars - 
along with the ICANN - only express a favourable view on the Program. And the 
brand owners - who are to finance the whole thing - and the average private 
internet user, none of whom have expressed any interest in this program, are 
not dominant in the debate and have no real influence on the realisation or not 
of the Program.

ICANN has recently issued a very interesting report prepared for them, namely 
the following:

"Economic Considerations in the Expansion of Generic Top-Level Domain Names 
Phase II Report: Case Studies - prepared for ICANN"


On its page 7, the following is stated:

"Consumers generally benefit from additional competition, which reduces 
quality-adjusted prices and/or increases variety, including the introduction of 
new products and services. Based on an examination of available data, however, 
our earlier report concluded that past gTLD introductions (e.g., .biz and 
.info) have not had significant competitive impact on .com's dominance in the 
registration of second-level domain names"

Does this fit with the motivation given by ICANN to the new program? - No, it 
does not.

On the page in which ICANN presents the program for readers "New to the 
Program", you can read the following:

"Since ICANN was founded, one of its foundational principles has been to 
promote competition in the domain name marketplace while ensuring Internet 
security and stability. The expansion of gTLDs is expected to allow for more 
innovation, choice and change to the Internet's addressing system."

"The expansion of gTLDs is expected to allow for more innovation, choice and 
change to the Internet's addressing system" says ICANN (see above), but where 
is the documentation?

There is NO documentation available supporting the conclusion that the internet 
suffers from "insufficient competition in the domain name marketplace", ALL is 
based on unsupported "expectation".

In our view this whole Program should be HALTED until sufficient and convincing 
documentation has been produced. If such documentation cannot be produced, 
which the above conclusions from the Economic Case Study seem to suggest, the 
Program as a whole should be cancelled, sooner rather than later. Enough 
resources have now been spent by the internet community on this stillborn 

The fact of the matter is that the only entities that are in favour of the 
Program are the ones who can make money out of it, and that is ICANN and the 

The "internet community", including private users and brand owners, are NOT 

There is no available documentation which contradicts that it is not both easy 
and cheap to acquire and use suitable domain names under the current system and 
there is no documentation showing that significant improvements would be 
obtained with the proposed Program, especially not when taking into 
consideration the enormous costs which are involved.

Søren Ingemann Larsen
Trademark and Domain Name counsel
H.Lundbeck A/S
Ottiliavej 9
DK-2500 Copenhagen Valby
Dir.: +45 3643 2123
Mob.: +45 3083 2123
Fax: +45 3643 8301

Attachment: 2011.01.11 Lego comments.pdf
Description: 2011.01.11 Lego comments.pdf

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