Minds + Machines AGB comment

[Elaine Pruis <elaine@xxxxxxxxxxxxxxxxxxxx>]

Dear ICANN,

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