dotBERLIN Comments

["Dirk Krischenowski | dotBERLIN" <krischenowski@xxxxxxxxxxxx>]

The dotBERLIN GmbH & Co. KG, planning to apply for the .berlin top-level
domain, would like to comment on the competition and pricing report as
follows:

In summary we support the contents of this report, which summarizes like no
other published paper a diversity of aspects of new and existing top-level
domains. Studies like this as well as the recent Gandi report help not only
the Internet community but also governments, businesses and others to
understand the domain name business and ICANN's role in it.

But what the report and many actors of the global Internet community have
lost sight of is the question what economic scenario would happen if no new
TLDs are introduced. I would like to dig up an old but still very virulent
reason why new TLDs are vital to be added to the root: The Alternate Root
Threat.

It is obvious that several large countries will quickly establish their own
root systems. China and several other countries may even be waiting for this
opportunity with alternate roots operating in their countries for years. The
damage to the global Internet by a fragmented root will not only harm
ICANN's role as a provider of a ubiquitous and reliable network but also
global business, in particular that of trademark owners, some of which
heavily try to prevent new TLDs.

Another aspect of studies like that from Dr. Dennis Carlton is that it is a
hard job to predict the future in highly dynamic areas like the Internet and
computing. I would like to remind you of predictions of this kind which
entirely failed, such as this one: "I think there is a world market for
maybe five computers" (Thomas Watson, IBM-Chef, 1943).

The report also underestimates the creativity of entrepreneurs but also
criminals to develop great ideas but also bad ones, but conserving the DNS
at the current status is definitely not the answer.

In the case of GeoTLDs we think that ICANN is definitely not in the position
to deny a request of city and regional governments who decide to have their
own TLD, regardless the potential economic value of these TLDs.

A last word: To "lower prices" may not necessarily mean to have lower domain
prices, it can also mean that with a domain like www.soho-plumber.london a
small business needs much less SEO than with www.soho-plumber-online.net.

Dirk Krischenowski
Founder and CEO
_______________________
dotBERLIN GmbH & Co. KG
Akazienstrasse 2
10823 Berlin
Germany
Tel +49 30 49782354
Fax +49 30 49782356
Mobile +49 173 2339156
Skype "krischenowski"
Web www.dotberlin.com