Comment from Annalisa Roger on Draw Process

[Tim Switzer <timswitzer@xxxxxxxxxxxx>]

As the single string applicant for the .GREEN TLD and with plans to launch and 
operate this valuable and important TLD name space offering global public 
benefit, and in support of the overall success of the new gTLD program, I want 
to thank you for the recent progress made and for the open discussions in 
Toronto relating to the New gTLD process. 

I am writing to provide input and comments on two specific New gTLD topics:

-       String Contention Resolution and ICANN Auction clarity around process 
and timeline

-       Process for Drawing for prioritizing New gTLD Applications, 
specifically related to string contention sets

Resolution and Auction Timing

In Section 4.1.3 and 4.3 of the New gTLD Guidebook, it describes the string 
contention self-resolution and auction processes.  What is not described in 
clear terms (especially with the Prioritization Draw being a new process) is 
the timing, especially as it relates to how long the self-resolution process 
takes and when the ICANN Auction process kicks in.  It is critical that a clear 
and well mapped-out process exist so as to ensure contention sets that 
ultimately are resolved by ICANN Auction are not delayed any further than 
necessary. 

A suggestion would be to set an exact timetable limit for the self-resolution 
process (i.e. 30 or 60 days) immediately and automatically, before the ICANN 
Auction process begins.  All applicants may agree to move the auction date 
sooner, but not later.  This would eliminate unnecessary idle time, false 
control or advantages to some by purposely staving off resolution with others, 
unknown auction dates for financiers, and it will ensure that the parties 
interested in providing a new TLD online can immediately move toward resolution 
and eventual delegation of the TLD.   I believe this would also allow ICANN to 
have an efficient scheduling of a third party Auctioneer with a regular 
time-table.

The Draw as it relates to the prioritization for contention sets and 
non-contention strings 

In order for contention strings to have a fair and equitable chance at a 
favorable draw (and more importantly, for their place in the cue in the entire 
process), I would like to suggest that after IDNs, all other strings are 
entered into the draw instead of individual applicants.  The same “per 
application” cost of $100 would apply and if there is a contention set of six, 
then $600 would be collected from each applicant.  I strongly believe and 
suggest that each string should be drawn for one position, not each applicant. 

In other words, if .ABC had 6 applications, then .ABC as a string will be 
entered into the drawing and whenever it is selected,  all 6 applicants would 
be evaluated at the same time based on the string draw position.  This ensures 
all strings have an equal chance of moving to their next step which would seem 
to be the fair and objective process and does not advantage or disadvantage 
contested vs. non-contested strings.  It also allows resolution for contention 
to begin right away.  The winner of the contention then assumes the draw number 
as its own and continues through to the next ICANN step.  The draw is supposed 
to control what order each applicant moves through the entire process, but with 
some having to wait for their entire contention set to clear the draw, a fair 
prioritization doesn’t take place and the draw becomes a disadvantage to anyone 
in contention. Those not in a contention will also have a difficult time 
assessing the timing of their priority number as so many applicants ahead of 
them may be waiting for contention sets.  Please avoid the unknown for the 
applicants (which a draw number is intended to provide) and create a model 
where each string has a fair and equitable chance of a favorable draw by 
drawing strings not applicants. 

Thank you for the opportunity to submit these comments.     

Sincerely,

 

Annalisa Roger

Founder and CEO

DotGreen Community Inc.