Comment from United TLD Holdco. Ltd.
United TLD Holdco, Ltd. ("United TLD") wishes to submit this comment in response to ICANN's request for comments on the Use of a Drawing for Prioritizing New gTLD Applications. First, United TLD applauds ICANN for proposing a random drawing to determine the order which new gTLD applications will proceed to contract negotiation, pre-delegation testing, and final approval and acceptance into the DNS. We believe that the draw proposal is logical and fair and, most importantly, will enable the new gTLD program to move forward and stay on the timeline established by ICANN. United TLD also supports ICANN's decision to give IDNs priority and allow them to go first in the draw ahead of other applications. While United TLD acknowledges ICANN's sound reasons for giving IDNs first priority, it feels strongly that ICANN should not consider also giving priority to other types of applications. We are aware that other applicants are now also asking for priority for their applications but the notion of giving multiple applications priority seriously undermines and erodes the fairness of the draw proposal and would also result in further delays to the process. In addition, although we support the draw proposal, we do not believe that the draw number should be used to determine the order that applications are released from initial evaluation. Initial evaluation results should be released as soon as they are completed. There is no logical basis for holding back evaluation results simply because of a draw number and doing so makes the application process less efficient. United TLD also urges ICANN to reconsider limiting the number of pre-delegation testing slots to 20 per week. We note that ICANN recently issued an RFP seeking proposals from one or more pre-delegation testing providers and that this RFP states that the provider be capable of conducting as many as 100 tests per week. Furthermore, because many applicants make use of the same technical backend provider, it should not be necessary to perform pre-delegation testing for every TLD. Rather, testing should occur only once on each backend provider, a number that is far fewer than even 20. Also, on the topic of auctions, United TLD suggests that ICANN conduct all auctions within 90 days from the date that the last application in a contention set has completed the initial evaluation process. This will create more certainty around the string resolution process and the timing of auctions. Finally, we believe that in order to adhere to the current timeline, it is crucial that all GAC advice on applications be issued no later than the close of the ICANN Meeting in Beijing. We ask ICANN to urge the GAC to work diligently to meet this deadline even if that requires a face-to-face inter-sessional meeting of the GAC prior to the meeting in Beijing. Statton Hammock United TLD Holdco, Ltd. ________________________________ Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Demand Media, Inc. Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you.