Comments from Costco Wholesale Regarding Expression of Interest Proposal

["Leigh Fulwood" <LFULWOOD@xxxxxxxxxx>]

Dear ICANN:

Thank you for soliciting comments on your proposal to implement a
pre-qualifying process for organizations who seek to operate a new gTLD.
As we understand the process, in order to submit an application to
operate a gTLD at some later time, when the qualifications and rules are
more final, an organization would have had to submit an early expression
of interest, along with a $55,000.00 fee.

Setting aside for a moment whether the Internet communities need new
gTLDs, and that fact that ICANN committed to resolving some of the
troubling issues surrounding the proliferation of gTLDs prior to
introducing new gTLDs, when the proposal to create new gTLDs was first
publicized the world' was different.  In most developed countries the
economy was strong, and organizations were comparatively flush.  That is
not so now.  In fact, many of the non-commercial organizations, such as
cities or special interest communities, who have been mentioned as
examples of beneficial gTLD operators, are simply in no position to
spend $55,000.00 for the privilege "expressing interest" in operating an
Internet domain.  Some commercial interests likewise may hesitate to
initiate a preliminary application process that costs tens of thousands
of dollars.  The proposed process at this time is likely to result in
fewer gTLD applicants overall, and the universe will be skewed away from
non-commercial interests.  A more fair way for ICANN to proceed would be
to tell the world exactly what it will expect of a gTLD applicant, so
that the applicant may make an informed decision prior to submitting its
application, and its fee.  

Very truly yours,

Leigh Fulwood
Corporate Counsel
425.313.6504
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