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Minds + Machines AGB comment

  • To: 6gtld-guide@xxxxxxxxx
  • Subject: Minds + Machines AGB comment
  • From: Elaine Pruis <elaine@xxxxxxxxxxxxxxxxxxxx>
  • Date: Sun, 15 May 2011 08:21:43 -0700


Thank you for the opportunity to comment one more time on the Applicant Guidebook (AGB) and the policy development for new gTLDs. This is the seventh time over the last three years that the public has submitted comments. Since at least the December 2010 ICANN meeting in Cartagena, no new information has been brought to light for consideration, therefore our submission will be general and brief. The AGB has evolved into a program that fully protects rights, yet retains objective standards for launching new gTLDs.

The new gTLD program was proposed to offer more choices, better service and lower pricing to consumers through competition. The potential public benefit of new TLDs has already been demonstrated by the IDN Russian TLD, .РФ, which has more than 800,000 registrations in fewer than five months of operation. The recent re-launch of the .co ccTLD, marketed to businesses that have been squeezed out of the saturated .com space has also been wildly successful. The public is hungry for more domain options, and the new gTLD program answers that need, even while strongly protecting consumers, trademarks, and governments from bad actors.

In fact, the AGB provides more protections than any other policy put into practice up to this point. Trademark holders (and therefore consumers) will benefit from at least ten new protection policies that are not in place in current gTLDs, including:

- Legal rights objections
- Thick whois
- Trademark clearinghouse
- Mandatory sunrise process
- Mandatory post-launch IP Claims
- Uniform rapid suspension (URS)
- Incentives for providing a high security TLD
- Dedicated points of contact at registries for abuse issues
- Enhanced and mandatory cooperation with law enforcement by registries
- Registry post-delegation dispute resolution process
- Increased scrutiny of applicants
- Removal of orphan glue records (to inhibit spam)
- Centralized method of zone file access.

The policy development that has taken place over the last several years has benefited from the input of many Internet constituents. The ISOC, IETF, INTA, software companies, international aid organizations, law enforcement, academics, and many governments have contributed to the process. No part of the ICANN community or the Internet community at large has lacked for opportunity to present their contributions and to have them fairly considered.

Finally, we note that ICANN policy development is in continual evolution, and fully expect the AGB and the new gTLD program to flex and transform as innovation occurs and the rapid expansion of the internet proceeds. On June 20th the ICANN Board should vote to accept the AGB.

After several years of working toward a program that provides for everyone's essential needs, we look forward to the final acceptance of the AGB and the launch of the new gTLD program. The ICANN Board should keep it's commitment to a June 20 vote in order to preserve the legitimacy of the consensus driven policy making program.

Elaine Pruis
VP Client Services
Minds + Machines

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