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Statement of the Boersenverein on closed gTLD ".book"

  • To: "comments-closed-generic-05feb13@xxxxxxxxx" <comments-closed-generic-05feb13@xxxxxxxxx>
  • Subject: Statement of the Boersenverein on closed gTLD ".book"
  • From: "Skipis, Alexander" <Skipis@xxxxxxx>
  • Date: Tue, 5 Mar 2013 15:03:35 +0000

Dear Sir or Madam,

the Börsenverein des Deutschen Buchhandels e.V. represents around 1800 
publishers and 6000 booksellers in Germany. One of our goals is the protection 
of the interests of our members and a level playing field for their commercial 
interests. In this capacity, we strongly object to the awarding of closed 
generic TLDs such as "book" to individual commercial entities, especially to 
those operating within the book industry.

In the gTLD Applicant Guidebook, ICANN's President and CEO Rod Beckstrom states 
the goals of the new gTLDs to "promote[s] competition and consumer choice" 
(http://archive.icann.org/en/topics/new-gtlds/rfp-clean-19sep11-en.pdf). In our 
view, the creation of closed gTLDs of generic words runs completely contrary to 
these goals: in fact, competition will decline and consumers will have less 
choice. In the long run, granting use of closed gTLDs could promote a shift in 
the Internet from being a public space to a collection of privatized islands or 
walled gardens. Similarly to the case of trade marks (where generic terms may 
not be registered), reserving the use of generic terms as gTLDs for individual 
companies is not desirable. From the point of view of consumer choice, locating 
a class of goods and a choice of suppliers with the help of the TLD is by far 
preferable to its leading to a single producer or retailer.

Closed gTLDs should only be granted for brand names or terms in which the 
applicant possesses established intellectual property rights and / or 
trademarks. Otherwise nation-states' established legal procedures for obtaining 
intellectual property rights and trademark protections could be circumvented or 

Nine different entities have applied for the "book" gTLD - despite the high fee 
which applies. This clearly shows the high level of interest in this particular 
gTLD and gives an indication of the enormous potential it would offer an 
exclusive proprietor. If any of these applicants were granted the exclusive use 
of the gTLD this could de facto further strengthen the position of a single, 
already powerful operator and would be detrimental to the book industry as a 
whole. In e-commerce markets for books and e-books which are already dominated 
by a small number of strong players, this could lead to damaging foreclosure 
effects and the reinforcement of oligopolistic market structures, to the 
detriment of consumers.

At the very least, the winning applicant must be obliged to make the gTLD 
available without discrimination for registrations by all eligible parties, 
including all commercial entities within the book industry. Granting the "book" 
gTLD exclusively to a single company would also make it impossible for the 
public to participate by registering and using second level domains under this 
TLD. Such participation, however, would advance the development of 
topic-related groups of domains which are beneficial to all Internet users.

Yours sincerely,

Alexander Skipis
Managing Director

Börsenverein des Deutschen Buchhandels e.V.
Braubachstraße 16
60311 Frankfurt am Main
Telefon: +49 69 1306-310
Fax: +49 69 1306-300

Attachment: Statement_Boersenverein_gTLDs.pdf
Description: Statement_Boersenverein_gTLDs.pdf

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