Yes to EOI but no to pre-application

["Dirk Krischenowski | dotBERLIN" <krischenowski@xxxxxxxxxxxx>]

The .berlin view on the EOI
**********
We have been a supporter of the idea of an Expressions of Interest (EOI)
procedure from the very first day since we .berliners were planning to
suggest something similar to the EOI at the Public Forum at the ICANN
meeting in Seoul as well. Thus, we were glad to be a part of the small
bottom-up group which had been founded around this topic and we contributed
to the basic documents of the EOI with good intentions.

About 2 months later and after consultations with many parties and
eye-opening articles on the EOI from Kieren McCarthy
(http://forum.icann.org/lists/draft-eoi-model/msg00002.html) and Michael
Palage (http://forum.icann.org/lists/eoi-new-gtlds/pdfPb6kjX4VeQ.pdf) and
other commentators from the community we think different with a broader view
on the topic.

We are convinced that the EOI should not push the general gTLD application
process to an earlier date and thereby favor ICANN insiders and enabling
massive gaming of the gTLD landscape. The currently proposed EOI model will
lead to first-come, first-served claims of TLD speculators which will flood
the process with copycats and un-mature TLD projects.

Wildest dreams became true
**********
Additionally we are much more skeptical, not about the idea of an EOI or the
suggestions made by the community, but on how the EOI might be used by ICANN
in general. We all know that ICANN has been pressured from the very
beginning of the new gTLD process from various sides including the
US-Government, trademark owners and the incumbent gTLDs to delay or stop the
introduction of new gTLDs. Many topics that never had been an obstacle to
the introduction of new gTLDs before (gTLD rounds in 2000 and 2004) became a
reason to install working groups, committees and writing reports with public
comment periods. This resulted at the end of the day in delay after delay
for the new gTLDs that only the interest groups that are mentioned above may
have expected to happen in their wildest dreams.

The great delay
**********
The ugly truth is, though, that the date when new gTLDs will be available to
the public has never been farther away than today. When the new gTLD process
started at the end of 2005 many in the ICANN community were confident, based
on the 2000 and 2004 gTLD rounds, that new gTLDs would be online within 18
months somewhere in 2007. Today, 5 years (!) later, we know that this did
not happen and the timeline outlook is worse than it ever was. What was
presented at the GSNO meeting by ICANN VP Kurt Pritz on Dec 17th draws a
vague timeline on the wall that may have a silver lining, as some have said,
somewhere in later 2012. Probably, provisional and tentative of course. That
means roughly 30 months between today and the day our .berlin and other
gTLDs may be available to create choice, competition and diversity on the
Internet.

Will the EOI become the End of Interest?
**********
Based on the experience of the 6 years in which we have been part of the
ICANN community we are convinced that the in principle beneficial vehicle
EOI will be an excuse for further delays in the introduction of new gTLDs.
In this respect the EOI is like a Valium tablet that is offered to potential
applicants and the community. You can choose if you want to take this gift
and having a sedated view on the new gTLD process through through
rose-colored glasses, for the next couple of years. Or the "Expressions of
Interest" may become the "End of Interest", because neither the EOI nor the
gTLD process shows potential applicants a way into the root within an
acceptable timeframe.

The .berlin suggestions
**********
0) The EOI's sole purpose is to collect information for ICANN's new gTLD
process recource planning, not to become a separate gTLD pre-registration
process.
1) Running the EOI a.s.a.p. should be top priority for ICANN and the
community to finally gather valid information on strings and the applicant
landscape. The EOI procedure must not delay ICANN's important task of
resolving open issues such as trade mark protection. In doubt the EOI should
be cancelled.
2) The EOI must not be compulsory! Therefore nothing needs to be changed in
the running gTLD process.
3) We believe that there are already over 100 potential strings for that the
respective applicants would voluntarily contribute information about. Trust
in the crowd sourcing power of our community!
4) Questions 1-14 are sufficient for information collection, but applicants
may provide additional information.
5) Publication of all EOIs should be mandatory.
6) The EOI fee should not exceed US$ 55,000. 
7) Instead of being compulsory benefits for the EOI applicants could include
regular applicant-only briefings, one-to-ones with ICANN staff and other
services which not only benefit the applicants but also ICANN.


Dirk Krischenowski
Founder and CEO
_______________________
dotBERLIN GmbH & Co. KG
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