Reply Comments

[Jon Nevett <jon@donuts.email>]

Donuts agrees with the reply comments offered by Famous Four Media.  The Google 
comments and the BC comments authored by a Google representative go beyond the 
scope of this comment period and look to change aspects of the new gTLD program 
long resolved in the Applicant Guidebook (AGB).  The issue of indirect 
contention sets itself is not open to reexamination nor should we be trying to 
redefine relationships between applicants in direct and indirect contention.  
The Guidebook is clear on that point.  Rather, we need to examine the specific 
proposed auction design and rules offered by ICANN to implement the indirect 
contention set tenets of the AGB.

It is in that spirit that we again mention our support for the proposal in 
general, but would like to see more transparency in the bidding process.  The 
information policy during the auction is overly opaque and should be corrected 
to ensure that applicants know where they stand in the auction.  Similarly, the 
payment rule should be quickly examined further to ensure fairness for all 
applicants.  ICANN and PowerAuctions should examine the proportional payment 
rule and recommend whether that is better for applicants than the externality 
pricing payment rule or some modified proportional rule.  Any such review of 
these two issues should be done efficiently to ensure that the resolution of 
these TLDs is not delayed further.  

Thanks again to ICANN and its vendor for the proposal and finalizing the 
implementation of it.  

Best,

Jon Nevett
Co-Founder, Donuts Inc.