The Smart Internet Foundation Comments on the Proposed Changes to the New gTLD Registry Agreement
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 launched. 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. Regards, Irina Danelia Deputy Director The Foundation for Network Initiatives "The Smart Internet"