.BERLIN comment - Prioritize GeoTLDs

[".berlin | Dirk Krischenowski" <krischenowski@xxxxxxxxxxxx>]

This is a comment by dotBERLIN GmbH & Co. KG (.BERLIN application) to
ICANN's request for comments on the Use of a Drawing for Prioritizing New
gTLD Applications.


>>> IDN and GeoTLDs will drive ICANN's Success Story

In principle we welcome the DRAW proposal since it offers the possiblity to
provide ICANN with a much needed success story to regain trust in the global
Internet community. However the proposal lacks one important part of public
interest TLDs: the Geographic Name gTLDs.

The prioritization of over 60 applications from all ICANN regions for
Geographic Name gTLDs (GeoTLDs) along with the IDN gTLDs offers a unique
chance to be one of the basic modules of the ICANN gTLD success 
story.


>>> Public Interest representing Governments have reminded ICANN for GeoTLD
Prioritization

We would also like to let the ICANN community know that at least a dozen
city and regional governments have written to ICANN during the past months
to support the prioritization approach, even before the prioritization
proposal was in place. ICANN regrettably did not publish these letters nor
gave a feedback although some local government have been empowered by their
national government or have filed the application themselves.

Additionally, several Governmental Advisory Committee (GAC) representatives
have stated their their request to prioritize GeoTLDs along with the IDNs at
the ICANN meeting in Toronto. 
This engagement of the GAC representatives is based on their role as
representatives from their respective national government, acting in the
public interest; as such they have to insist on the prioritization of
GeoTLDs.

The approval of GeoTLDs is tied to the requirement for government support or
non-objection as a core element of the GAC Principles Regarding New gTLDs
issued in March, 2007. These public policy principles were introduced to
safeguard the global public interest. Principle 2.2 says: "ICANN should
avoid country, territory or place names, and country, territory or regional
language or people descriptions, unless in agreement with relevant
governments or public authorities." 

With this background we are convinced that the GeoTLD applications fulfil
the requirements set by ICANN to give a priority to certain categories of
TLDs: to promote DNS diversity, make the Internet more accessible, increase
avenues of participation and serve the public interest.

Mingling applications for GeoTLDs (and IDNs) with other applications would
question ICANN's ability to prioritize and to work in the public interest,
an important and critical part of its mission. The GeoTLD applications are
virtue of the governmental support they obtained truly in the public
interest and must be an integral part of ICANN's upcoming success story.

-----------------------

Dirk Krischenowski
Founder and CEO
dotBERLIN GmbH & Co. KG
Akazienstrasse 2
10823 Berlin
Germany