Comments on Draft Expression of Interest/Pre-Registrations Model

[Doug Johnson <Djohnson@xxxxxxx>]

The American Bankers Association appreciates the opportunity to comment on 
ICANN's Draft Expression of Interest/Pre-Registrations Model (EOI).  ABA 
recommends that ICANN not move forward with EOI in its current form.  It is 
certainly appropriate for ICANN to gauge gTLD demand for the next round.  A 
central theme of ABA's recent comment letters has been the need to gauge 
demand.  However, the manner in which the EOI is structured, with mandatory 
participation and a $55,000 filing fee if an entity wishes to ultimately fully 
apply for a gTLD, has the potential of forcing participation in the EOI while 
many important issues regarding the potential for infringement, malicious 
conduct, and compromised Internet security remain unresolved.
Requiring an expression of interest to even be allowed to participate in the 
next round of gTLD applications pressures potential applicants to participate 
in the EOI process without full knowledge of how the overarching issues 
currently facing the round will ultimately be resolved.
Regards,

Doug Johnson
Vice President, Risk Management Policy
American Bankers Association

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