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ICANN Submission

  • To: "comments-gac-safeguard-advice-23apr13@xxxxxxxxx" <comments-gac-safeguard-advice-23apr13@xxxxxxxxx>
  • Subject: ICANN Submission
  • From: Christine De Mazières <cdemazieres@xxxxxx>
  • Date: Mon, 3 Jun 2013 12:20:00 +0000

Dear Sirs,

In the framework of the current ICANN consultation on the topic of "closed 
generic" gTLD applications, the French Publishers Association (SNE) would like 
to express its support to the submissions of the International Publishers 
Association and the Coalition for Online Accountability.

The French Publishers Association (SNE) is France's trade association of book 
publishers. It represents approximately 600 member companies whose combined 
business endeavors account for the bulk of French publishing and whose total 
turnover was close to 3 billion € in 2012 (4.3 billion € expressed at the 
retail selling price). The SNE's missions include advocating publishers' 
interests, supporting creativity by defending freedom to publish and promoting 
the respect of intellectual property rights,  promoting and defending fixed 
book price, and promoting literacy.

The attribution of a new gTLD such as .book is a strategic issue for sectors 
like publishing which are particularly dependent on copyright. The SNE would 
thus like to express its opposition regarding any applications for a “closed 
generic” gTLD, most notably .book, .read and .author. This exclusivity of use 
of a specific gTLD by an economic actor would therefore deprive its competitors 
from using this level domain name. If a major distribution stakeholder had a 
monopoly over such essential strategic tools for e-commerce, this would have 
dramatic consequences on competition.

As pointed by the Governmental Advisory Committee in its Beijing Communiqué, we 
feel all the more concerned about the establishment of an exclusivity on a gTLD 
such as .book as it would be granted to a private company, although this would 
not be not be justified by a public interest goal .

The SNE therefore supports the advices of the Governmental Advisory Committee. 
It hopes that ICANN will follow them, in particular the six safeguards and 
especially for the sensitive string of industry sectors dependent on copyright 

In conclusion to minimize any unnecessary delay, ICANN should immediately begin 
a dialogue with the GAC to clarify the best way to implement the Advice. It 
should then work with applicants and the community to integrate key elements of 
the Advice into the contractual framework for the new gTLD registries. The 
result should be an improved program that more effectively achieves its stated 

Thank you in advance for your consideration of this letter.

Respectfully yours,

Christine de Mazières
Syndicat National de l’Edition

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