Network Solutions Comment on the Applicant Guidebook (April 2011)

["Hammock, Statton" <shammock@xxxxxxxxxxxxxxxxxxxx>]

Network Solutions appreciates the opportunity to comment on ICANN's sixth - and 
hopefully final - New gTLD Applicant Guidebook.  Once again, we commend ICANN 
for adroitly managing all of the community input and effort that has gone into 
the Applicant Guidebook.  We are especially pleased to see how the community's 
comments and concerns, including the comprehensive list of issues identified by 
the Governmental Advisory Committee (GAC), have largely been assimilated in 
this latest version.  

We also reassert our view that a document of this complexity and importance can 
never be "perfect" or "complete" in the eyes of every stakeholder member.  
Fortunately, in our view the Applicant Guidebook's current form substantially 
addresses most of the outstanding issues and is robust enough to support the 
launch of the new gTLD application process.  Of course, we also expect and 
believe that the Applicant Guidebook will evolve over time as ICANN becomes 
aware of issues or difficulties arising during the application process and the 
launch of the first new gTLDs.

We do have one concern that we believe must be addressed promptly.  The current 
Applicant Guidebook makes reference to "GAC consensus" and its ramifications 
for a new gTLD application.  We do not see a definition for such "GAC 
consensus" in the Guidebook, however, and feel that this term needs to be 
explicitly defined.  In fact, we are not confident that the ICANN community's 
concept and application of "consensus" matches that of the GAC and that any 
misunderstanding on this point will be detrimental to the new gTLD process, to 
potential applicants, and ICANN in general.

Sincerely,

Statton Hammock
Senior Director, Law, Policy & Business Affairs
Network Solutions, LLC