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dotHAMBURG Comments on the draft Expression of Interest (EOI) / Pre-Registrations model

  • To: draft-eoi-model@xxxxxxxxx
  • Subject: dotHAMBURG Comments on the draft Expression of Interest (EOI) / Pre-Registrations model
  • From: ""Oliver J. Süme"" <sueme@xxxxxxxxxxxxxxxx>
  • Date: Wed, 27 Jan 2010 16:28:19 +0100

Dear ICANN-Team,

please find attached the comments of dotHAMBURG on the draft model of an EOI /
Pre-Registration model.

• 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 EOI procedure must not lead to any further delays in the new gTLD process!

Best regrds,

Oliver Sueme
Founder / CEO
Initiative dotHAMBURG e.V.
Gertigstr. 28
22303 Hamburg

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