Comment from United TLD Holdco. Ltd.

[Statton Hammock <Statton@xxxxxxxxxxxxxxx>]

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.


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