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Support for the GAC Advice

  • To: "comments-gac-safeguard-advice-23apr13@xxxxxxxxx" <comments-gac-safeguard-advice-23apr13@xxxxxxxxx>
  • Subject: Support for the GAC Advice
  • From: Simon Little <simon.little@xxxxxxx>
  • Date: Tue, 4 Jun 2013 14:45:49 +0200

We represent the European video game industry which is now Europe's largest 
entertainment sector and is continuing to grow at a healthy rate. Video games 
are on the front line of cultural innovation: they represent a melding of 
technical ingenuity, software innovation, and artistic creativity. At their 
best they bring together the visual scale of film, the dramatic scope of novels 
and the spontaneous cultural creation of human interaction in unpredictable and 
never-before-seen ways. The video games industry has also been at the forefront 
of the development of the information economy. Games have constantly pushed the 
boundaries of the online experience, have been at the heart of the smartphone 
and tablet revolution, and are pioneering the use of high-intensity cloud 
The era of digital distribution has brought great change to the games industry, 
as it has to many others. Although existing business models have been 
challenged to evolve, entirely new forms of delivery, payment and interaction 
have developed alongside these existing models. Incredible opportunities have 
been created and seized. Proper management of the vital online infrastructure 
supporting our industry is vital and we applaud the work done by ICANN so far. 
We now join with a broad spectrum of creative sector organizations, including 
the Coalition for Online
Accountability, in urging ICANN to accept key elements of the New gTLD 
Safeguard Advice from ICANN’s Governmental Accountability Committee (GAC). 
I.  We feel that ICANN should welcome detailed advice from the Governmental 
Advisory Committee (GAC) on New gTLDs for the following reasons:
·      Incorporating major elements of the GAC Advice into the new gTLD program 
will increase the likelihood that the program will achieve the stated goals of 
expanding competition and enhancing consumer choice.

·      ICANN should work with the GAC to clarify any ambiguities in the GAC 
Advice, and with applicants and the community to integrate key elements of the 
Advice into the remaining stages of the new gTLD process.  
II.  We Commend GAC’s List of “Safeguards Applicable to all New gTLDs” (pp. 
·      These safeguards could significantly reduce the risk of abusive 
registrations in all gTLDs. GAC’s six step proposal to:
        1.  Conduct Whois verifications and checks
        2.  Adopt a responsible standard of terms of use
        3.  Perform periodic security checks
        4.  Maintain Statistical reports
        5.  Establish a complaints channel to flag abuses
        6.  Impose consequences when violations occur
comprises a set of common sense procedures that any responsible registry 
operator should be in a position to support and implement.  

·      These safeguards are neither unprecedented nor unanticipated.  Similar 
features already appear in the revised Registrar Accreditation Agreement (e.g., 
some requirements to verify Whois data and to enforce terms of use against 
illegal activity by registrants that infringe the rights of others). Many new 
gTLD applicants have already anticipated some of these safeguards in their 
applications (e.g., providing complaint channels for third parties and 
reserving the right to suspend or delete registrations used for abusive 

·      Our organisation endorsed similar safeguards a year ago, and urged 
ICANN, GAC, and all relevant new gTLD applicants to apply them.
·      In addition to our own organisation’s support, the Coalition for Online 
Accountability has also approved GAC’s 6 recommended safeguards as well as the 
five additional safeguards identified by GAC for sensitive strings.

·      Safeguards are especially vital for TLDs at higher risk of abuse that 
harms consumers or the rights of others. This includes applications targeted at 
sectors dependent on copyright and trademark protection who have consistently 
experienced high levels of online infringement and malicious attempts to 
redirect traffic respectively. Meaningful steps to anticipate and manage these 
risks should be mandatory. Thus, even if not required for all new gTLDs, the 
GAC’s six basic safeguards and five additional safeguards for sensitive strings 
should be mandated for those listed as such within the GAC Advice such as 
.games, .game etc. Among the additional safeguards for these listed TLDs (pp. 
8-9), #4 is especially important for giving affected industries such as our own 
a seat at the table.    

Yours sincerely, 

Simon Little

Simon Little

Managing Director

Interactive Software Federation of Europe (ISFE)

Brussels, Belgium

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