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The Smart Internet Foundation Comments on the Proposed Changes to the New gTLD Registry Agreement

  • To: <comments-base-agreement-05feb13@xxxxxxxxx>
  • Subject: The Smart Internet Foundation Comments on the Proposed Changes to the New gTLD Registry Agreement
  • From: "Irina Danelia" <irina.danelia@xxxxxxxxx>
  • Date: Wed, 27 Feb 2013 00:50:39 +0400

Dear Sir / Madam,


I am submitting these comments on behalf of the Foundation for Network
Initiatives "The Smart Internet", the applicant for TLD .ДЕТИ. The
applied-for IDN gTLD .ДЕТИ is considered a basis for a nationwide social,
non-for-profit project aiming at creation of sustainable and trusted
Internet environment for children and enhancement of the quality of usage of
the Internet by kids and teenagers.


This is to express our concern regarding proposed changes to the new gTLD
Registry Agreement, primarily the newly added section 1 of specification 11.
The proposed wording thereof requires registry operators to employ services
exclusively from ICANN Accredited registrars who are expected to execute an
RAA currently under negotiation. Not only would this requirement
unequivocally have an adverse effect on a potential distribution channel,
but it would also pose a significant risk to the successful launch of the
TLD and the associated project in question. 


The first issue is timing. Having gotten an early drawing number, we believe
our TLD will be delegated into the root zone in a not-so-distant future.
That said, the new RAA has not been finalized as yet, the negotiations are
still underway, and the text of the agreement has not been made publicly
available, nor there are any guaranteed RAA finalization timelines.
Therefore, the plausibility of a situation with TLD having already been
delegated into the root and the RAA still not approved is perilously high.


The other issue is a registrar's readiness to execute a new RAA. The .ДЕТИ
initiative focuses primarily on the Russian market. Meanwhile, out of a few
hundred of ICANN-accredited registrars, only three ones are based in Russia
and operate on the domestic market. Hence, the access to the distribution
channel proves to be increasingly obstructed by the binding requirement to
registrars to have signed the new RR agreement by the time of the TLD is


We believe the aforementioned concerns are not unique; rather, they might be
common for numerous IDN applications. Therefore, the ICANN's generous and
very laudable move to grant priority to IDNs is at risk of being seriously
compromised and, ultimately, blocked, should the spec 11 requirement in
question eventually retain its effect.


We recommend ICANN withdraw or revise this requirement. 




Irina Danelia

Deputy Director

The Foundation for Network Initiatives "The Smart Internet"



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