Comments on the Expressions of Interest process

[Avri Doria LTU <avri@xxxxxx>]

Dear ICANN,

I would like to state my comments for the current Expressions of Interest 
("EOI") process, and appreciate the opportunity to make my views heard.

OVERALL SUPPORT OR NON-SUPPORT FOR EXPRESSIONS OF INTEREST
I am opposed to Expressions of Interest. It grants preferential treatment for 
insiders.  

Other issues covered below.  

One thing I have noticed, the more I think about the idea, the worse I think 
the idea is.  Thank you for giving me this chance to work out some of my ideas. 

SUBMISSION FEE
There is discussion about the $55,000 (USD) submission fee.   I support a lower 
fee because it's fairer.     Lower fee = 0.  

The only possible valid reason I can see for an EoI is to give ICANN some idea 
of the scope of possible applications.  There is no reason people should have 
to pay for ICANN's ever delayed process.

MANDATORY NATURE OF EXPRESSIONS OF INTEREST
There is also a question about whether Expressions of Interest should be 
mandatory for those applying for a new TLD.  New TLD applicants should not have 
to submit an EOI.     We do not know the full conditions of the application 
given the unresolved 'overarching' issues.  That means that some people may 
still be trying to decide whether they want to apply or not.  

This is a marketing gimmick for the insiders.

REFUNDS
The current EOI model will provide refunds of the submission fee only in 
extraordinary circumstances, or unless ICANN is unable to accept new TLD 
applications by a particular date.  Refunds should be granted on demand     If 
conditions change from DAGv3 to DAGvX such  that, .e.g. it makes someone's 
application less feasible from a business perspective or the conditions change 
to make the TLD open to objection when it was not open to objection  
previously, then letting ICANN pocket the money, is unjust.

COMMUNICATION PERIOD
ICANN's draft EOI model contemplates a four-month communication period prior to 
accepting EOI submissions. Four months is about right for the communications 
plan.  Until such time as full outreach in all UN languages has been done, one 
canot say that 'everyone knows'.  This is just a Rich Northern presumption.

Of course I do not believe in EoIs at all, but if they must happen because the 
pressure is too great by some major players for the powers that be to say no, 
then an entire communications plan should play out first - a plan that not only 
explains the EoI plan and the new gTLD plan but which makes clear that there 
are no guarantees that the conditions one sees today are the conditions they 
will face when the real application process opens up.

PUBLICATION OF DATA
Finally, there is a question about whether data collected from EOIs should be 
made public. ICANN should publish all strings and applicants.  Again, I do not 
accept the necessity of EoIs and do not see it as being the right way to say 
"yes to new gTLDS' as some of the propaganda argues.  But if people are going 
to secure themselves a place in line to the exclusion of any newcomers, then 
those late to the party should know whom to contact to buy into, acquire or 
otherwise gain control of the new TLD application tokens.

And, incidentally, who will control the token, will it be transferable and by 
whom with what conditions?  I know so that it "does not harm the
security or stability of the DNS", but what does that mean, and what 
constraints will ICANN put on the transaction?

OTHER COMMENTS
I still believe it is prejudicial against potential applicants from 
developments areas.

And generally a really bad idea.
  

Signed,
Avri Doria 
LTU
avri@xxxxxx

[This comment comes via the ICANN comment form found at 
http://www.mindsandmachines.com/2010/01/let-icann-know-your-position-on-expressions-of-interest.
  This form provides brief descriptions of the issues and allows easy comment 
on the Expressions of Interest process.]