eco Association Statement on Universal Acceptance
Please find below a statement respectfully submitted by eco Association of the German Internet Industry, an Industry Association with more than 750 members from more than 60 countries. Thank you, Thomas Rickert Director Names & Numbers eco Association of the German Internet Industry (www.eco.de) eco welcomes ICANN's initiative and its continued efforts on the issue of Universal Acceptance. We agree that Universal Acceptance is a priority matter and that a sense of urgency needs to be created. eco appreciates that ICANN's actions are limited to its role and that Universal Acceptance is an issue that needs to be addressed by a variety of stakeholders. Nonetheless, there are areas of activity, which have been described in other comments as well as in the JIG final report, which are well within ICANN's mandate. The JIG report is a result of work conducted jointly by the ccNSO and the GNSO and this report spells out concrete actions. This begs the question why such concrete activities have not been mentioned in the Abridged Roadmap with performance indicators and timelines. While ICANN should play a role of active coordination and facilitation, there are measures that ICANN can and should implement immediately. ICANN claims to be globally inclusive. However, should ICANN not be able to evidence that adequate resources have been allocated to addressing the issue of Universal Acceptance and that appropriate measures, such as the ones described in the JIG report, have been taken, ICANN will have failed to be gobally inclusive. We do recognize that third parties need to take action to make all domain names work and that their actions or a lack thereof is beyond ICANN's control, but ICANN needs to at least reach out to those players. While Universal Acceptance is an issue for both both ccTLDs as well as gTLDs and also for ASCII as well as IDN TLDs in both categories, the new gTLD Program creates an additional challenge for ICANN. During the evaluation of the new gTLD Program, the question will have to be answered whether this program has provided for consumer choice and competition. Should new gTLDs not work for e-mail, popular browsers, social media or other critical applications, the potential benefits of new TLDs will not unfold as they otherwise could. It is not sufficient for ICANN to have established a process to delegate new gTLDs, but ICANN needs to deliver on its parts of a shared responsibility towards users so they can make full use of all existing and future gTLDs.