Comment in favor of EoI

[Alexander Schwertner | EPAG Domainservices GmbH <as@xxxxxxx>]

Dear ICANN,

I would like to extend my previous comment on the EoI proposal made
earlier during this comment period.

I think we need progress on the new TLD process more urgently than ever
before. Otherwise there is the risk that we will see many applicants for
new TLDs pulling out of the process due to the lack of confidence in the
ICANN process, and the resulting uncertainty for investors who are to
provide the substantial financial backing for a TLD as required by the DAG.

The EoI proposal, in addition to the benefits it provides for solving
open issues which I have outlined in my previous comment, can provide
the first firm launch date in the near future. This would reinforce
confidence in the progress and predictability of the new TLD process.

ICANN aims at broad participation in the new TLD application process. To
outsiders, who are to be the target of the communications campaign, the
year-long and unpredictable new TLD process, with ever-postponing launch
dates and new issues brought up again and again, is very disencouraging.
Would an "outside" investor still want to allocate substantial funds
into a TLD project that relies upon on the success of this ICANN
process? If we want innovation based on the DNS, we should make sure to
keep ICANN policy making competitive. The longer our community takes to
finalize the process, the smaller the eventual audience of applicants
will be. This is not about lack of economic demand - this is about
scaring away potential innovators by policy making gotten out of hand.

The EoI proposal will not launch new TLDs - but, if the EoI comes, it
proves that ICANN is able to make decisions that lead into real action
in this process.

Regarding the issue brought forward by several comments that an EoI
should not be a pre-application window for insiders, I would like to
underline that in the current EoI proposal the same level of
pre-communication is suggested as was originally conceived for the
launch of the application itself. It's the same for month global
communication campaign, the only difference being that now it's for the
EoI instead of the actual application. It is not earlier as originally
planned - until mid of 2009, a start of the actual application phase in
the first half of 2010 was anticipated.

If, however, the pre-application issue is concerned to be substantial,
my suggestion would be to call for EoI, publish the strings afterwards
and then allow other applicants to apply for strings within this pool.
This approach would serve to determine the maximum number of TLDs and
type of strings to be applied for, while eliminating any market for a
secondary market for TLD application slots. This is in any case a better
solution than discarding the EoI and try to continue solving the issues
by guessing number of TLDs.

I again encourage ICANN to move forward with the EoI process soon and
take a decision on the proposal at the Nairobi meeting at the very latest.

Alexander Schwertner
Managing Director

EPAG Domainservices GmbH
Rheinallee 3
53173 Bonn
Germany
http://www.epag.de