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ICC Task Force Chair & Vice Chair's input on EoI--Submission

  • To: <draft-eoi-model@xxxxxxxxx>
  • Subject: ICC Task Force Chair & Vice Chair's input on EoI--Submission
  • From: "ICC" <ayesha.hassan@xxxxxxxxxx>
  • Date: Wed, 27 Jan 2010 11:17:51 +0100

Attached please find informal comments from ICC's ITIS Task Force Chair
and Vice Chair on the EoI draft proposal, in html and word formats.

Please ensure that both formats are uploaded, and please ensure that the
comments are designated as "ICC's ITIS Task Force Chair and Vice Chair's
comments on the EoI draft proposal"

Many thanks,

Ayesha Hassan


ICC Task Force on Internet and Telecom Infrastructure and Services (ITIS) Chair 
and Vice Chair?s Informal comments on Draft Expressions of 
Interest/Pre-Registrations Model (EoI)

ICC, the International Chamber of Commerce, is a global business membership 
organization, with companies and associations from the supply and buy sides, 
across sectors and geographies, and of all sizes. As the Chair and Vice Chair 
of ICC?s Task Force on Internet and Telecoms Infrastructure and Services (ITIS) 
we appreciate the opportunity to provide informal comments on the proposed 
Draft Expressions of Interest/Pre-Registrations Model. Our members all rely on 
the Internet for many facets of their operations, communications, and 
distribution channels, thus the technical coordination of the Internet is of 
critical importance to them.

ICC members place significant importance on both the ?Affirmation reviews? and 
the ?EoI?. We have managed to develop consensus informal comments on the 
?Affirmation reviews? which will be submitted by the deadline. Given the 
simultaneous comment periods for these two important topics, the end of year 
holidays, and the need to respect ICC?s internal consensus building processes, 
we regret that we cannot submit complete and consensus built input on this 
important topic of the EoI. In this context, we submit the following points for 

- The draft Expression of Interest (EoI) proposal has interesting elements. 
However, ICC does not support the implementation of any EoI until the rules for 
the new gTLD application process are at least fully developed and agreed upon 
by the ICANN community.

- An EoI is not a substitute for an independent economic analysis on the demand 
for new gTLDs, which was requested by the Board in October 2006 to be conducted 
prior to the launch of an EoI and the first application round for new gTLDs.[1] 
We request that this study be conducted.

- It is very difficult for business to evaluate participating in an EoI when 
new or changed gTLD application rules could significantly impact business plans 
and models. There are still several important issues that remain unresolved in 
the current Draft Applicant Guidebook (DAG), and it is not certain they will be 
resolved by DAG4.

- We believe the EoI proposal should be discussed more fully and publicly with 
the ICANN community at the next ICANN meeting in Nairobi and would be concerned 
if the EoI proposal is meant to be decided by the ICANN Board in February. We 
recommend that a dedicated and comprehensive discussion take place at the next 
ICANN meeting in Nairobi before any final decision is taken on this matter.

We appreciate the opportunity to provide these informal comments in our 
leadership capacities for ICC?s relevant task force and look forward to 
contributing to the continued discussion related to new gTLDs.

Gordon Moir, Chair, ICC?s Task Force on Internet and Telecoms Infrastructure 
and Services (ITIS)

David Appasamy, Vice Chair, ICC?s ITIS Task Force

27 January 2010 AH/ams

The International Chamber of Commerce (ICC)

The International Chamber of Commerce is the largest, most representative 
business organization in the world. Its hundreds of thousands of member 
companies in over 120 countries have interests spanning every sector of private 

A world network of national committees keeps the ICC International Secretariat 
in Paris informed about national and regional business priorities. More than 
2,000 experts drawn from ICC?s member companies feed their knowledge and 
experience into crafting the ICC stance on specific business issues.

The United Nations, the World Trade Organization, and many other 
intergovernmental bodies, both international and regional, are kept in touch 
with the views of international business through ICC.

For more information please visit: www.iccwbo.org

ICC Commission on E-Business, IT and Telecoms (EBITT)

Business leaders and experts drawn from the ICC membership establish the key 
business positions, policies and practices on e-business, information 
technologies and telecommunications through the EBITT Commission. With members 
who are users and providers of information technology and electronic services 
from both developed and developing countries, ICC provides the ideal platform 
to develop global voluntary rules and best practices for these areas. Dedicated 
to the expansion of cross-border trade, ICC champions liberalization of 
telecoms and development of infrastructures that support global online trade. 
ICC has also led and coordinated the input of business around the world to the 
World Summit on the Information Society, Geneva 2003, Tunis 2005, and continues 
this effort in the activities established in the Tunis Agenda through its 
initiative, Business Action to Support the Information Society (BASIS 

[1] ICANN Board request on economic study available at 

Attachment: ICC ITIS TF Chair Vice Chair's input on EoI 27Jan10.doc
Description: ICC ITIS TF Chair Vice Chair's input on EoI 27Jan10.doc

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