ISOC-AU comments on gTLD Guidebook
The Internet Society of Australia (ISOC-AU) is a non-profit society founded in 1996 which promotes the Internet development in Australia for the whole community. ISOC-AU is a chapter of the worldwide Internet Society and is a peak body organisation, representing the interests of Internet users in Australia. We have a longstanding and ongoing commitment to the effective representation of these interests in self-regulatory processes in the telecommunications, domain name and Internet-related services industries.
We welcome this opportunity to provide the following comments on the New gTLD Programme: Draft Applicant Guidebook.
Technical Testing Criteria (5.2.1)We strongly support the criteria relating to IPv6 that an applicant must be able to substantiate in its application. Specifically, we strongly support the requirement that a registry both supports provisioning of IPv6 services for its registries and access to DNS servers over an IPv6 network. ISOC-AU has hosted conferences on IPv6 for the past four years, and there is a considerable amount of valuable information on transitioning to IPv6 available on our website (www.isoc-au.org.au). The IPv6 Forum and our IPv6 Forum Downunder are also valuable sources of information (www.ipv6forum.org and www.ipv6forum.org.au)
Grounds for objection (3.1)The ‘legal rights’ ground for objection cannot be clear cut. The law on trademarks, and intellectual property is not universally consistent. What amounts to 'standing legal rights' in one jurisdiction may very possibly not be recognised in other jurisdictions.
Morality and Public Order (184.108.40.206)The explanation in the back of the Guidebook explains that objections on these grounds will be based on generally accepted international conventions (such as on Human Rights and fundamental Freedoms). Because such conventions are generally accepted internationally, they should form a sound basis for dealing with such objections.
ICANN’s remit (and expertise) is, however, the security, safety and operability of the DNS system. Because objections based on morality and public order will be based on international treaties/conventions, ICANN should seek advice from those qualified in the are before upholding objections on these grounds.
Cost considerationsWe recognise that the application process to ICAN,N should be cost based, and that registrars should be contributing annually to ICANN’s ongoing costs. However, the purpose of opening up the GTLD space should be to encourage a range of new TLDs that meet a range of community as well as corporate requirements. The initial application fee of $185,000 plus the annual fee of $75,000 may be far too high for legitimate, smaller communities (or communities of interest) who would otherwise benefit from their own TLD. ICANN should give consideration on how those community interests could be addressed, either through a discount of those fees or a special grants program for such communities.
Guidebook LayoutFinally, with some minor changes, the content of the document could be made far more user-friendly. We recognise that the primary purpose of this Guidebook is to assist applicants. However, with some reordering or the material, and better pagination, information that is valuable to users seeking to understand the new gTLD processes would not be overlooked. For example, each section has its own page numbers, so it is not possible to readily find material being referred to. Each Module also contains material which is explained in the Explanatory Memoranda section, but that material is not referenced in the Modules (and would be difficult find anyway without better pagination). Cross referencing and beter pagination would make the guidebook a more readable and valuable resource.
Kind regards Holly Raiche Executive Director, Internet Society of Australia (ISOC-AU) ed@xxxxxxxxxxxxxx Mob: 0412 688 544 Ph: (02) 9436 2149 The Internet is For Everyone