comment on closed-generic gTLD applications

[Ron Wickersham <rjw@xxxxxxxxxxxxxxxxx>]

i am submitting this comment as an individual, but am a member of NCUC.
it represents my views and does not represent the position of NCUC.

the community bottom-up policy development that culminated in the AG
involved a lot of effort and deliberation and compromise of all those
participating and those who's input was rerlayed to the group.   the
AG cannnot be easily abandoned, nor would it be in the interest of
ICANN participation to sweep aside the policy resulting from this long
deliberation.   but in the discussion, there was understood to be the
concept of .brand generic-closed domains, and some community domains 
operated in the public interest.
i do not recall any hint of closed domains that would capture generic
category words and if those were anticipated by some participants in
the discussions, they were relatively quiet about their intentions to
later promote this type of domain business model.    thus the Board
has observed that the AG is silent on this topic, and yet is aware of
the controversial result of a large number of closed-generic applications,
thus the request for comments on an issue not addressed face-on by the
AG.

my enthusiasm for supporting generic word categories as logical extension
of .com, etc. TLDs is fundamentally dependent on the openness of these
extended domains.    i also support .brand domains and carefully vetted
.community domains.

so with reluctance, i oppose the concept of allowing category generic
TLDs that are closed, in spite of the expectations of those who have
made detailed business plans which assume that they would have only
other closed seekers and face auctions to resolve conflicting applications.


the world-wide public interest is worthy of careful consideration in
approving applications, even at this late date.

-ron wickersham