Comments from .berlin (dotBERLIN GmbH & Co. KG)

[Dirk Krischenowski | DOTZON GmbH <krischenowski@xxxxxxxxxx>]

I'm writing on behalf of the Registry dotBERLIN GmbH & Co. KG which is the 
contracted operator of the .berlin gTLD.



I have read and analyzed the recently released study "Phase I Assessment of the 
Competitive Effects Associated with the New gTLD Program" which evaluated the 
competitive effects associated with the New Generic Top-Level Domain ("gTLD") 
Program (https://www.icann.org/news/announcement-2-2015-09-28-en).



Surprisingly, the study does not make a single mention of the category of 
GeoTLDs. Most of the GeoTLDs including .berlin are operated under specific 
economic conditions and in the public interest, based on a letter of support of 
their respective government(s). As a consequence, a huge part of successful new 
gTLDs have not been properly addressed in the report.



As you might know, almost all GeoTLDs have a contract with their relevant 
government(s). Those contracts often preserve public interest commitments which 
significantly exceed what ICANN requested in Specification 11. In terms of 
competition, the contracts have in many cases ambivalent consequences, as a 
number of GeoTLD operators are obliged to pay fees to their governments. Thus, 
a relevant number of GeoTLDs have extra payment obligations in average between 
US$ 3.00 to 10.00 per domain name.



While many larger ccTLDs and gTLDs have a wholesale price around US$ 2.00 to 
7.00 (resulting in end user prices between US$ 3.00 to 20.00), most GeoTLDs 
must charge a wholesale price of US$ 10.00 - 30.00 in order to sustain their 
operations. The average end user prices for GeoTLDs are about between US$ 20.00 
and 60.00.



Even with these additional obligations, the GeoTLDs are among the most 
successful new gTLDs. I have communicated these facts to responsible ICANN 
staff and the editors of the assessment study, along with specific numbers and 
examples, starting in February 2015 and more extensively at the ICANN meeting 
in Buenos Aires.



I'm disappointed that the study's performance and results do not address those 
topics adequately, as commented at 
http://domainnamewire.com/2015/09/29/new-tld-competition-report-is-worthless. I 
believe that differentiation between generic gTLDs, geographic gTLDs and 
possibly other relevant categories of gTLDs needs to be reflected in future 
ICANN studies. I suggest that the specific conditions under which GeoTLDs are 
being operated need to be analyzed more thoroughly and considered in further 
economic studies on new gTLD competition, diversity, innovation and consumer 
choice.



I'm more than happy to contribute to this as this matter is also important in 
the process to review and develop future rounds of the New gTLD Program.



Regard,



Dirk Krischenowski (CEO)

26 October 2015 (originally submitted but the comment was not published)