dotHotel comments on the Draft EOI/Pre-Registrations Model

[Johannes Lenz-Hawliczek | HOTEL Top-Level-Domain GmbH <johannes@xxxxxxxxxxxx>]

Hotel Top-Level-Domain GmbH (dotHotel) comments on Draft Expressions
of Interest/Pre-Registrations Model

dotHotel was among the initial supporters of the Expressions of
Interest proposal and participated in the ad-hoc working group which
tried to suggest a procedure which would provide useful data for ICANN
while being leight-weight at the same time. What we have seen as a
result from there on looks like yet another excuse for yet another
delay in a process that for some has lasted close to five years now.
What’s more, some observers have commented that the EOI may well be
used by speculators for purposes which were definitely not intended
from our side. While we don’t believe that ICANN should try to strive
for a situation were either nobody or everybody is an insider, we
clearly do not support any scheme that might encourage a gaming of the
new gTLD process. While we still support the original concept of the
EOI proposal, these considerations have caused some second thoughts on
the EOI on our side.

Please find our comments to the EOI and pre-registration model below:

• Responses to the request for EOI are mandatory for eligibility to
submit a gTLD application in the first round. Subsequent application
rounds are open to any eligible applicant.

Comment: Since the final requirements have not been defined yet the
EOI must be voluntary. It should also not be treated as a
pre-registration process.

• A deposit of US$55,000 is required for the EOI, as a credit against
the evaluation fee.

Comment: The EOI deposit should be reasonable. 

• The deposit is refundable if the New gTLD Program does not launch
within a specific time period.

Comment: If the application or registration process does not start
within 6 month after filing the EOI, the amount shall be refunded.

• Participants are notified that there will be subsequent changes to
the Applicant Guidebook, and that there are limited terms for refund
based on such changes. It is the intention to conclude many
outstanding issues (for example, discussions of issues concerning
vertical integration and the IDN‐3 character issues) prior to
initiation of the EOI process, through the publication of draft
version 4 of the guidebook.

Comment: To start a process and call it pre-registration without the
final requirements approved by the ICANN board is against ICANNs
practice and not acceptable. All that is needed now is basic
information as to the number of potential applicants. ICANN should
provide other incentives for the parties to participate in the EOI
process.

• A fully executed communications campaign, intended to ensure global
awareness of the program, will precede the opening of the EOI process.

Comment: The EOI communications campaign should substitute any further
communication campaigns.

• A specific set of information concerning the participating entity
and the intended string is collected from EOI participants.

Comment: The information gathered should be limited to the minimum
needed to achieve the initial goal of the EOI – numbers and kinds of
applications.

• The participant and string information will be made public.

Comment: We think this should be voluntary since there are a number of
valid reasons which could stand against a publication of this
information. In cases where the applicant does not wish his name and
the string to be published, the data should be anonymized instead.

Having stated all of the above, we urge ICANN to complete the gTLD
process as quickly as possible! The global hotel industry is waiting
to have its own address. The EOI procedure must not lead to further
delays in the new gTLD process!

Best regards

Johannes Lenz-Hawliczek

CEO, Hotel Top-Level-Domain GmbH (dotHotel), Berlin, Germany