Comments by Constantine Roussos (.MUSIC Initiative & MyTLD)

["Constantine G. Roussos" <costa@xxxxxxxx>]

Dear ICANN,


Thank you for the opportunity to comment on the Applicant Guidebook
Discussion Draft (Version 6). I would also like to thank ICANN staff and the
Board for their continued effort on finalizing the Guidebook as well as
actively working with GAC to reach a consensus position on any remaining
issues. It is noteworthy to mention that the Trademark Community and
ultimately consumers will benefit considerably from the extensive trademark
protection mechanisms that are in place in the new round of gTLDs that are
absent from current gTLDs.

* Two-Character Labels *

Reservation of Two-Character labels is a new topic that has not been
discussed but added in the guidebook regardless. There is no correlation
between Two-Character codes and new ccTLDs in regards to new gTLDs. A
"U2.music" domain clearly denotes the URL of the band U2. A "DJ.music"
denotes "DJ Music" not the country of Djibouti. Adding a Two-Character
reservation policy will not only limit the allocation of domains to rightful
owners (such as U2, TI and other artists) but will restrict new gTLD
operators from launching appropriate premium domains to be used to benefit
consumers and stakeholders. There are many country-codes such as .MY, .TV,
.DJ that the general public considers generic and would not confuse with
countries, especially if the gTLD suffix clearly denotes the content-matter.
Another issue that might arise from implementing reserved two-letter codes
is legal concerns when brands are not able to get their name. For example,
HP.printer.

*IDN Bundling*

IDNs are a benefit to non-Latin Internet users and promoting and supporting
the Internationalization of the Internet is integral to ICANN. Bundling of
transliterated/translated (tt-gTLD) IDN versions of a Latin-based
application would help expand ICANN's vision and goals and serve the global
needs of non-Latin script users. Applications with IDN bundles will not
require ICANN to review the same application numerous times because Bundles
will fall under the same Applicant with the only differentiating factor
being the IDN transliteration thus saving ICANN time and significant costs.
A bundled IDN application can share ICANN review, legal and time costs. Each
additional tt-gTLD (within the same application) should only incur an
additional cost equivalent to the cost associated with the DNS Stability
Panel Evaluation. As a benchmark for cost determination, it was noted that
the estimated cost in the IDN Fast Track ccTLD Process was $6000 per string.
Since the gTLD Program is more extensive, that IDN bundle cost per IDN
string is expected to be slightly higher than that. Furthermore, if there
are any additional costs, these may still appear in extended evaluations as
well.

Looking forward to the final acceptance of the ICANN gTLD Guidebook and the
launch of the new gTLD program on June 20th. Again, kudos to ICANN staff and
the Board for all their continued hard work and addressing the remaining
issues using a consensus driven approach.

Constantine Roussos

.MUSIC Initiative
http://www.music.us

MyTLD
http://www.mytld.com