eco e.V. Comment on draft EOI and Pre-Registration Model

[Thomas Rickert <rickert@xxxxxxxxxxx>]

The below comments are made on behalf of eco, the Association of the
German Internet Industry (www.eco.de). eco is the German ISP and
Internet Industry Association with about 500 members from different
Internet industry sectors. The association represents over 200 ISPs and
Registrars forming the backbones of the German Internet.

- eco supports the concept of the EOI process.

- We strongly believe that the EOI will be helpful in assessing and
resolving the root-scaling concerns and staff administrative workload.
As a consequence, the EOI is likely to enable ICANN to speed up the new
gTLD process.

- A communication campaign to be launched as soon as possible is
necessary to inform as many interested parties as possible. However, the
communication campaign should substitute other awareness campaigns.

- The EOI should not be mandatory. Even though a communication campaign
will help raising awareness, it may not reach all relevant parties.
Therefore, those applicants who did not participate in the EOI should
not be excluded from the possibility to participate in the first
application round. Those, who have participated in the EOI could be
eligible to receiving additional services from ICANN as an incentive for
participation. Additionally, we assume that applicants who are seriously
interested in applying will participate in the EOI anyway to raise their
profile and that the number of those applying without having
participated in the EOI will low enough not to dilute the results of the
EOI.

- The EOI should be a "firm" EOI round requiring accurate particpant
data and a deposit. However, the data gathered should be limited to what
is needed to answer the questions that shall be answered by means of the
EOI and the deposit should not exceed the amount of 55.000 USD.

- Applicant data and strings should be kept confidential upon the
applicant's request and the respective EOIs should be published in an
anonymised form. This would also reduce the risk of the participation in
the EOI being a disadvantage if additional players can enter later.
Additionally, such approach helps to reduce the risk of litigation
against a participant of the EOI in a phase where the actual application
is not yet certain.

Best regards,

Thomas Rickert, Rechtsanwalt

Director Self-Regulation



eco - Verband der deutschen Internetwirtschaft e.V.

Lichtstraße 43h, 50825 Köln

www.eco.de