Comment from John Poole, Editor of DomainMondo.com, and domain name registrant

[John Poole <jp1@xxxxxxxxx>]

To ICANN:

Comment from John Poole, Editor of DomainMondo.com
<http://www.DomainMondo.com>, and domain name registrant

Re: ICANN's gTLD Marketplace Health Index (Beta): Call for Comments
<https://www.icann.org/public-comments/gtld-marketplace-health-beta-2016-07-19-en>

1. I repeat and incorporate by reference, as if fully set out herein, the
entirety of my comment
<https://forum.icann.org/lists/comments-gtld-marketplace-health-17nov15/pdfQsziB8ArJy.pdf>
found here:
https://forum.icann.org/lists/comments-gtld-marketplace-health-17nov15/pdfQsziB8ArJy.pdf
submitted on January 8, 2016, in response to your earlier gTLD Marketplace
Health Index Proposal: Call for Comments
<https://www.icann.org/public-comments/gtld-marketplace-health-2015-11-17-en>.
You have ignored not only my earlier comment referenced above, but most of
the other comments submitted at that time, including comments by ICANN's
own Business Constituency and IPC, all of which can be read here:
https://forum.icann.org/lists/comments-gtld-marketplace-health-17nov15/.

2. Your gTLD Marketplace Health Index (Beta) is severely flawed and should
not be used. You have failed to define the "marketplace" properly, you have
ignored "pricing" as a key component of determining "Marketplace Health"
(you should be tracking, and publishing daily, wholesale and retail
pricing, as well as corresponding registration numbers, for each and every
TLD in the global DNS if you are indeed interested in "Marketplace
Health"). You are measuring such metrics as "geographic diversity" which
may be irrelevant or invalid for reasons I discussed in my earlier comment
and which your "expert" Professor Hemant Bhargava
<https://www.icann.org/en/system/files/files/economic-evaluation-gtld-performance-metrics-20jun16-en.pdf>
also cited. We live in a global economy. GoDaddy and other registrars do
business worldwide via the internet. Wake up ICANN, it's the 21st Century!
(Get out of your "hub" mentality and into a "global" mentality.)

3. It appears ICANN management and staff are too incompetent, inept, or
conflicted, to develop a useful, relevant and valid domain names
"Marketplace Health Index." I would suggest taking note of all the comments
submitted previously and this time, and outsourcing the entire project to
CENTR https://www.centr.org/ and/or the Internet Society
http://www.internetsociety.org/ or some other entity competent to do the
job.

Respectfully submitted,
John Poole
Editor of DomainMondo.com <http://www.DomainMondo.com>, and domain name
registrant