EoI may be a problem for development regions/countries and the less endowed applicants

[Avri Doria <avri@xxxxxx>]

The ICANN Staff proposed model discusses various risks, but not all risks.  A 
major risk it ignores is that applicants from developing regions or less 
developed sectors of the economy will be further discouraged from participation 
in the new gTLD process. That is, the effect of the model on the developing 
world and those who do not have ICANN style deep pockets is neither discussed 
nor reviewed. 

The ICANN Staff report recommends making this process expensive and making it a 
prerequisite for the first round. This is not in the public interest and I 
believe it is against the principles of competition guaranteed by the ICANN 
Bylaws and agreed to in the AoC.  It seems to take the Draft Application 
Guidebook (DAG) process that is already strongly biased in favor of incumbents 
with deep pockets and makes it even more biased in that direction.

Putting any cost on the EoI will constitute a further barrier to entry to 
applicants from development regions. It is obvious now that full funding for 
new gTLD applications will not be needed until 2011 or later as expressed on 
page 12 the EoI model  ”(e.g., 18 months from the closing date of the EOI 
submission period - could push us to 2012).”  Until the latest slippage in 
schedule, one could have assumed that there were at least 9 months until 
funding would be required.  With the introduction of a required EoI with an 
expensive price tag, any applicant will need to have a significant amount of 
money in hand now in order to gain a 'license' to apply sometime in the future. 
 It is difficult enough for some future applicants to keep a small group of 
workers focused on an ever slipping application target, but to require them to 
pay for the privilege of waiting in line is cynical.

The EoI, as currently planned, compounds the injury of the exorbitant 
application fees featured in the DAG. The question asked by the Government 
Advisory committee (GAC) concerning whether the pricing could be made fair to 
those whose economies whee still developing has not yet been answered.  Now, 
even before that question has been answered, or better yet some provision 
having been made, those entrepreneurs from development regions need to assert 
their claim. And to do so they will need to come up with a large player’s fee 
before they know how these issues will be resolved.  They will need to pay 
$55,000 just for the privilege of standing in line.

This is not in the public interest of those from the developing world who are 
waiting to finally be allowed entrance into the world of gTLDs.