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HKIRC / .MTR's Comments on Use of a Drawing for Prioritising New gTLD Applications

  • To: <drawing-prioritization@xxxxxxxxx>
  • Subject: HKIRC / .MTR's Comments on Use of a Drawing for Prioritising New gTLD Applications
  • From: "Henry Chan" <henry.chan@xxxxxxxx>
  • Date: Fri, 9 Nov 2012 11:38:18 +0800

Dear Sir/Madam,

Hong Kong Internet Registration Corporation Limited (HKIRC), the registry of
the .hk and .香港ccTLDs, submits the following comments on Use of a Drawing
for Prioritising New gTLD Applications on behalf of the .MTR new gTLD
application, in HKIRC's capacity as the application’s consultant. The same
is attached in a PDF file for your use.

Overall comment:

HKIRC welcomes the opportunity to provide inputs on the proposed plan for
prioritising new gTLD applications.

Considering the long delay caused by the technical problems of the TLD
Application System (TAS) earlier this year and the introduction and
subsequent termination of the “Digital Archery” batching method, we opine
that the community cannot afford further delay caused by more changes in
policies and procedures of the application process after this round of
public consultation. We also urge ICANN to process the applications as
quickly as possible with their best endeavour and to avoid further deviation
from policies and procedures set forth in the Applicant Guidebook (AGB),
which was the foundation of applicants’ understanding and expectation of
the rules and procedures when they applied for their new gTLDs.

In the following, we will provide our specific comments on different parts
of the proposed plan. We hope the below suggested modifications will improve
the overall fairness, efficiency, and reliability of the proposed plan.

Prioritisation drawing:

As expressed during the “Prioritization Drawing” session of the ICANN 45
Toronto meeting, we opine that there should be a first round drawing for
every applicant, so that applicants with single applied-for
string/application will have an equal chance of getting prioritised as
applicants with multiple applied-for strings/applications. 

Hence, there will be two rounds of drawing. In the first round, the total
draw numbers available will equate the total number of applicants.
Applicants with single applied-for string will draw a number for that string
application while applicants with multiple applied-for strings will have to
choose one string among their portfolio to participate in the first round

After the first round drawing and when a queue has been formed for every
applicant, a second round drawing will be conducted for all applied-for
strings which have not been included in the first round drawing. The draw
numbers available for the second round drawing will follow the queue formed
during the first round drawing.

This method of drawing where multiple applications applicants have to
prioritise their own portfolio before taking part in the ICANN
prioritisation process had been one of the prevailing views of the community
even before the current plan was proposed. Moreover, HKIRC was not the only
community members who suggested this method during the “Prioritization
Drawing” session of the ICANN 45 Toronto meeting. As a result, we urge
ICANN to modify the drawing solution to reflect the community’s view as
suggested above.

We are aware of some community members’ view of adopting a “round-robin”
approach in drawing between IDN new gTLD applications, which have been
proposed to be prioritised in the overall drawing, and other applied-for
strings. While we do not oppose such approach in principle, we opine that
the “round-robin” approach could only be incorporated into the above
suggested two-round drawing method where every applicant (including the IDN
applicants) will have one equal opportunity of getting prioritised in the
first round drawing.

ICANN arranged proxy for drawing ticket purchase:

We would like to reiterate our comment made during the “Prioritization
Drawing” session of the ICANN 45 Toronto meeting that we expect more
details to be furnished the soonest regarding the ICANN arranged independent
proxy for drawing ticket purchase in USA. This is very important for
applicants who cannot afford or do not intend to attend the drawing in USA
in person to be confident that the ICANN assisted proxy appointment will be
reliable and free from human error. 

Price of the drawing ticket:

During the “Prioritization Drawing” session of the ICANN 45 Toronto
meeting, we queried the price of the drawing ticket. We learned from ICANN
that the fee collected from the drawing process would be contributed to
charity. While acknowledging the fact that any charitable fundraising would
only be viable when a reasonable threshold of fund raised can be reached, we
urge ICANN to keep the price of the drawing ticket as low as possible
because applicants have already paid a large amount of application fees for
the process. Moreover, it would be desirable if applicants are allowed to
choose the charitable organisations they want to contribute to via the
drawing ticket purchase.

Pre-delegation testing, contract signing, and delegation:

We are of the view that ICANN should not impose an arbitrary limit of ~20
per week for the processes of pre-delegation testing, contract signing, and
delegation at IANA. We advise ICANN to review the situation from time to
time and ramp up the processes whenever resources allow.


Henry CHAN
Manager, Business Development
Hong Kong Internet Registration Corporation Limited (HKIRC)
Tel: +852 2319 3830
Mobile: +852 9034 0174
Fax: +852 2319 2626

Attachment: Comments on Use of a Drawing for Prioritizing New gTLD Applications (HKIRC).pdf
Description: Adobe PDF document

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