comments on ccTLD Delegation and Redelegation User Instructions and Source of Policy and Procedures

["Leonid Todorov" <l.todorov@xxxxxxxx>]

Thank you for the opportunity to submit our comments.

1)      It would be appropriate to disclose the costs of servicing a CCTLD
registry in a most detailed manner, including all the items concerned. This
would help promote the maximum level of transparency in the ICANN's
operation.

2)      As a registry which operate both the IDN TLD (the biggest one to
date)  and a "normal" cctld, our sense is that with the current rigid
financial framework, IDNs are discriminated against "normal" cctlds, and the
contribution brackets for IDN can effectively discourage their expansion by
setting the respective fee due to ICANN 1) on too high a level and 2) with
the use of the progressive scale. This, again, calls for revision and
disclosing data referred to in  para 1) above, as well as for uniformity of
technical requirements to all the TLDs

 

Sincerely,

Leonid Todorov

Coordination Center for    TLDs for Russia