EOI/Pre-Registration Model Draft (Comment by Interlink Co., Ltd.)

["横山 正" <yokoyama@xxxxxxxxxxxxxxx>]

Dear ICANN,

Interlink is grateful for ICANNs willingness to seeking public comment
on this issue.
We have carefully reviewed the EOI process and would like to offer the
following comments:

The plan as a whole offers an alternative solution to issues that are
holding back the new gTLD program.  It appears to be a fair, thought
out plan for applicants who have a developed plan and are ready to
begin the application process.

Deposit Fee -

In the “Firm” model, there is a necessity for participants in the EOI
to show a hight level of commitment, therefore, putting roughly 30
percent of the application fee up front should be a non-concern for
serious participants, so long participation in the EOI process is
compulsory for all first round applicants.

Refunds -

The refund criteria needs to be expanded, and very specific.  Losing 5
to 10 percent of one’s deposit due to changes in the applicant
guidebook that render the application invalid should be backed by a
full refund.  Will a refund process exist if an application is dropped
due to similar or identical strings?

Communication Period -

It is our estimation that applicants waiting on the commencement of
the first round have been monitoring developments in the program since
at least the Paris meeting.  However, the communication period is an
important way to make sure that all potential applicants are on the
same page. The communications period should begin the moment the EOI
draft is approved by the board.

Gathering of Data -

We echo the previous comments of Kieren McCarthy.  “The model misses a
vital opportunity to gather useful data that could be made anonymous,
analysed and published to give everyone a better overall perspective
of the new gTLD process.”

As the model stand now, the reconciliation of all current overarching
issues could not be completed with the current set of required data.
However, the required data is a base for gauging the level of interest
in the new gTLD program as well as helping ICANN ensure that ICANN can
plan for operational readiness.

So long as the work on the EOI process does not hinder the progress of
gTLD program we   believe it is a step in the right direction.  Many
members of our community have doubts as to when and if a second round
of applications may come about.  Moving forward with the EOI may
assist in making a second round more realistic and in the near future.

We thank ICANN for the opportunity to share our thoughts and
appreciate the time other community members have used to comment in
this forum.

Sincerely,

Tad Yokoyama
CEO
Interlink Co., Ltd.