DOTZON comments on Draft Expressions of Interest/Pre-Registrations Model

["Katrin Ohlmer" <katrin@xxxxxxxxxx>]

Please find enclosed our comments on the EOI.

The EOI was initiated to provide ICANN staff with more planning reliability
by providing data on key open issues. This refers to how many applications
will there be in the first round, and what kind of strings will be filed. In
the meantime it looks like the EOI replaces the perennial, bottom-up
consensus based gTLD process in parts with a pre-registration process that
favors insiders and encourages speculators. It even supports new business
models just filing an EOI for speculative reasons, and after publication of
the string approaching the TLD applicants with good faith to get a "golden
handshake" from them for drawing back the application.

Please find below our comments based on the feedback of our clients (German
brand owners):

1. The EOI must be voluntary, since some of the overarching issues have not
been solved yet. To start the application process or so-called
pre-registration process without a clear definition of requirements is
against ICANNs practice and not acceptable. Incentives for the EOI
applicants could include regular applicant-only briefings, one-on-ones with
ICANN staff and other services.

2. The EOI deposit should be a reasonable amount, and depend on the category
of the application. If the regular application window doesn't open within 6
month after filing the EOI, the amount shall be refunded.

3. The EOI communications' campaign should substitute any further
communication campaigns.

4. The specific set of information gathered should be limited to as few
information as necessary relating to the initial goal of the EOI - numbers
and kinds of applications. With regards to the publication of this
information we oppose the suggested public availablility. German companies
don't want to publish their application for strategic issues - so
publication of the EOI applications should be anonymized by categories and
without the entities' name. 

In summary, we urge ICANN to reconsider the scope and effectiveness of the
EOI with regards to the initial goals of the EOI. We would like to encourage
ICANN to complete the gTLD process as soon as possible to keep faith in
ICANN, and foster competition and choice for consumers through new gTLDs.
The EOI procedure must not delay ICANNs task of resolving the few remaining
overarching issues.

Thanks for the opportunity to comment!

Best regards,
Katrin Ohlmer
CEO, DOTZON GmbH

DOTZON GmbH - incubating name spaces
Berlin, Germany
www.dotzon.com