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GAC on EoI

  • To: <draft-eoi-model@xxxxxxxxx>
  • Subject: GAC on EoI
  • From: "Janis Karklins" <janis.karklins@xxxxxxxxx>
  • Date: Tue, 26 Jan 2010 21:46:53 +0100

Mr. Peter Dengate Thrush

Chairman of the Board


Paris, 26 January 2010



Re: GAC advice to the ICANN Board regarding the EoI process




Dear Peter,


The GAC appreciates the efforts of the Board and staff to explore the
possible benefits and downsides of an Expression of Interest (EoI) phase for
the new gTLD program. GAC recognises that such a process could help provide
data on key questions relating to root scaling, staff administrative
workload, and the different types of strings in the first round. 


However, there is still significant ambiguity about the purpose of such an
EoI: mere data gathering or mandatory pre-registration. GAC notes that in
the latter case the EoI could have a significant impact on the new gTLD
program and that it should not prejudice the treatment of some outstanding
policy issues.


In this context, the GAC would like to express concerns regarding the
consultation process, including that: 


-      the first call for comments in November – December 2009 had very
limited visibility and duration;


-      the objections raised in those limited consultations were not
sufficiently examined in the summary of comments prepared by staff; 


-      no request has been made for GAC’s opinion, despite the clear public
policy implications of the proposal (cf. Article III Sec 6 1 c. of the
Bylaws); and


-      if the Board takes a decision in February 2010 on the EoI, there will
have been no opportunity for face-to-face community interaction on this
important new proposal before the final decision (contrary to Article III,
Sec. 6 2 of the Bylaws). 


To co-ordinate the global Domain Name System in the public interest, and
make its decisions in an accountable and transparent manner as requested by
the Affirmation of Commitments, ICANN must provide an opportunity for broad
cross-community interaction on this important process before final decisions
are made. 


The GAC believes that the risks raised by the current draft EoI proposal
must be more thoroughly evaluated. In particular, the proposed EoI model


-      give an unfair advantage to some ICANN participants[1] who could
pre-empt the most valuable strings before the rest of the world is fully
aware of the gTLD program; 


-      allow a speculative market for “EoI application slots”; and


-      penalize developing country applicants, and small non-profit TLD
projects that none-the-less operate in the public interest.  


GAC recalls its March 2007 Principles on new gTLDs and intends to provide
further comments on the EoI proposal before or at the Nairobi meeting,
taking into account reactions by the community and comments posted.


In view of the above, the GAC therefore advises the Board to:


-      avoid taking a decision on the EoI at its February meeting and defer
it until the next ICANN Public meeting. A premature decision could trigger
requests for reconsideration and further derail the discussion;


-      request that staff facilitate a full cross-community deliberation on
the EoI at the next ICANN Public meeting, prior to any final decisions; and


-      ensure that the second summary of comments clearly documents the
respective interests of respondents.  


The GAC would welcome the Board’s early consideration and response to this



Yours sincerely




Janis Karklins

Chairman of the Governmental Advisory Committee,

Ambassador of Latvia to France




[1] The Affirmation of Commitments states: “ICANN and the Department of
Commerce recognize that there is a group of participants that engage in
ICANN's processes to a greater extent than Internet users generally. To
ensure that its decisions are in the public interest, and not just the
interests of a particular set of stakeholders, ICANN commits to perform and
publish analyses of the positive and negative effects of its decisions on
the public, including any financial impact on the public, and the positive
or negative impact (if any) on the systemic security, stability and
resiliency of the DNS.”

Attachment: GAC to ICANN 100126 EoI.doc
Description: MS-Word document

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