New gTLD Program - Draft Expressions of Interest/Pre-Registrations Model : Comment

["Ursula le Roux" <Ursulalr@xxxxxxxxxxxxxxx>]

Smartcall is fully committed to the "firm" EOI process where accurate
participant data and a deposit are required. Participation in the EOI
must be mandatory for eligibility to submit a gTLD application in the
first round. Smartcall also believes that the participant and string
information should be made public.

 

Smartcall agrees that a deposit must be required for the EOI and that it
should be used as a credit against the $185,000 evaluation fee.

 

ICANN estimate that there will be approximately 500 applications for the
EOI process. This will inevitably lead to the situation where some of
the applied for strings are identical. Smartcall's biggest concern
(raised in previous comment rounds) is that some participants will be
lucky and get an exclusive string whilst others will be in contention
with competitors. In some cases the competitor may be a huge corporate
with vast sums of cash.

 

To avoid these types of issues participants should be allowed to submit
an application with up to 10 strings in order of preference. If there is
contention with their 1st choice then they should be offered the
alternative of:

1)      Withdrawing (with a percentage of the deposit refunded)

2)      Keeping their choice and moving forward with the process with
the understanding that they may end up in an auction

3)      Dropping their first choice and moving to the second choice in
the list. The contention will then be gone.

4)      If the 2nd choice also results in contention then the process
continues until all 10 choices have been considered.

By adopting this process, all participants will be given a fair chance
to obtain an exclusive string without having to worry about
participation in an auction. 

 

The alternative process, offering participants the opportunity to submit
a second string after the 1st EOI round if there is contention is not
viable. This is because 2 organisations could work in collusion and
submit the same string in EOI round 1 with the knowledge that they will
get a 2nd chance in EOI round 2 and they will know all of the other
applied for strings.

 

The EOI does not cover the situation where 1 organisation wants to apply
for 2 strings. If an organisation does want to do this then, under the
currently proposed rules, must it submit 2 applications with 2 deposits
etc. Smartcall feels that this option also needs to be fully clarified.

 

 

Ursula le Roux|IT Manager| Smartcall (Pty) Ltd | 
Ursulalr@xxxxxxxxxxxxxxx <mailto:Ursulalr@xxxxxxxxxxxxxxx> | Office:
+27.11.507.4777

 

 


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