Use of a Drawing for Prioritizing New gTLD Applications (Comment)

[新gTLD <newgtld@xxxxxxxxxxxxxxxxxxxxx>]

Dear ICANN,

We believe that the drawing mechanism is appropriate, yet some 
modifications should be made as follows.

A. Issue of one applicant with multiple applications 

There is a clear probability benefit for those who applied for more than 
one application. To foster competition, ICANN should avoid this; ICANN 
should ask applicants with several applications to select a priority and 
then establish several rounds of drawing in this way:

   1. IDN draw.
   2. First draw: single application applicants and the top priority 
   application for multiple application applicants.
   3. Second draw: the second priority application for multiple application 
   applicants.

And so forth.

B. Issue of competitor 

Many applicants’ concern is not their absolute time to market but their 
relative time to market. This is how separated their TLD delegation is from 
that of their competitors. Under the current drawing system, if their 
competitor was to be number one and the applicant last, the difference 
between the delegations could end up being more than one year, which is not 
acceptable.

A solution could be to ask each applicant to name up to three or five 
strings that they themselves consider being a competitor. After all links 
have been established, a group of competitors are created and these subsets 
of competitors would be drawn together. The order between subsets could be 
established randomly since absolute time is not so important as long as an 
applicant is in the same subset as the competitors.

NOTE: To avoid conflicts with applicants with multiple applications, the 
selection of three/five competitors should be done among the ones in the 
same draw (from point a). Otherwise, if point (a) is not implemented, 
multiple application applicants should only be allowed to select up to 
three/five competing applications overall against a TLD they applied for.


Regards


New gTLD Team

Brights Consulting Inc.