Asociación PuntoGAL comment on Draw Process

[Manuel Vilas <manuel.vilas@xxxxxxxxxxxx>]

Asociación Puntogal, applicant of a new gtld for Galician language and
culture, congratulates ICANN for the removal of the Digital Archery system.

PuntoGAL sees the Prioritization Draw proposal as less unfair than the
Digital Archery system, but at the end of the day still unfair. If ICANN
does not introduce any prioritization and launches a 100% pure draw,
portfolio and trademark applicants will be favored, because they are the
bigger group among applicants. Therefore, a 100% pure draw will work
directly against ICANN's objective of expanding the cultural diversity of
the Internet, which is one of the stated objectives of this new gTLD
process.

PuntoGAL supports the GAC request included in its Toronto communique:
"geographic name gTLDs approved by the relevant government authority,
community names and applications from developing countries should likewise
be prioritized".

PuntoGAL contends that the reason for prioritization of the categories
specified by the GAC is the same as the one ICANN uses in its proposal to
prioritize IDNs. PuntoGAL agrees that IDNs will contribute to the promotion
of cultural and linguistic diversity on the Net, but IDNs will achieve this
to the same degree than, for example, community domains designed and
launched by linguistic and cultural communities.

Therefore, not granting cultural and linguistic domains the same priority
as IDNs will discriminate these community domains for the simple fact of
using the Latin alphabet.

PuntoGAL acknowledges that at this stage of the new gTLD process it is
difficult to create a new category of applicants in order to comply with
GAC advice about prioritizing community domains because of, in GAC words,
their "global public interest". The solution is to use the resources that
are in the submitted applications.
The community applicants that should be prioritized are the ones who have
demonstrated their "public interest" by including a letter of support or
non-objection signed by the competent public authority in compliance with
AGB rules. It is very simple to identify the members of this group.
Reviewing annexes included by applicants already included in the community
category will be enough.

Because of the large number of applicants in the group prioritized
according to its global public interest (IDNS, community proposals with a
letter of support or non-objection by a public authority, proposals from
developing countries and geographic names), a prioritization system inside
this group is needed. This prioritization can be achieved by the Draw
system already proposed by ICANN.

In addition to this priority group, PuntoGAL suggests that candidates
should be able to let ICANN know that they would agree to enter the stages
of the process at the end of the queue. ICANN should bear in mind that
there is a relevant group of candidates who seek a new gTLD solely for
defensive purposes.

PuntoGAL also proposes that applicants should be able to form groups in
order to get just one number from the Draw. Using this approach, .yellow,
.red and .pink should be able to get just one number from the Draw. This
will not harm anyone and the members of the groups will be able to avoid
the main danger of batching for them, which is for .yellow being on the
root one year later than .red. Logically, ICANN should limit the size of
the groups, for instance, to the amount of gTLDs that they are able to
delegate in one week.

Finally, PuntoGAL insists that ICANN's first goal should be to avoid any
new delay. The new gTLD process kicked off years later than the dates
initially published by ICANN. This generated very significant problems for
all applicants. After the difficulties experienced with TAS and Digital
Archery, it will be very complicated for the Internet community to
understand that the Draw, or any solution adopted, pushes back the current
calendar, which ensures that all Initial Evaluations will be published in
June-July 2013. This deadline should be kept to at any cost.