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GeoTLDPriorization Comment from Key-Systems GmbH

  • To: drawing-prioritization@xxxxxxxxx
  • Subject: GeoTLDPriorization Comment from Key-Systems GmbH
  • From: Volker Greimann <vgreimann@xxxxxxxxxxxxxxx>
  • Date: Fri, 09 Nov 2012 17:33:41 +0100

Key-Systems GmbH, an ICANN accredited registrar and shareholder of dotSaarland GmbH, a new gTLD applicant respectfully submits the following comments:

First of all, we would like to congratulate ICANN for making signifficant headway in the new gTLD program by the removal of the seriously flawed Digital Archery system and replacing it with a much more thought out and more transparent metering system as well as creating a defined timeline for the final steps of the process. Creating and keeping to a definite timeline is an important factor to further the trust and confidence in the ability of ICANN (and by extention the multi-stakeholder model) to successfully implement and carry out a project of this scope and magnitude.

However, we do believe this system still needs a few tweaks in order to better comply with ICANN's stated objective of the new gTLD process of promoting cultural diversity in the internet by recognizing the special importance of TLDs which correspond to geographic names ("geoTLDs"). Currently, the system only gives priority to IDN TLD applications as they promote the global public interest even though the very same global public interest is served by another category specifically defined in the AGB.

We therefore agree with the GAC request included in its Toronto communique that /"geographic name gTLDs approved by the relevant government authority, community names and applications from developing countries should likewise be prioritized"/. In accordance with the requirements of the Applicant Guidebook for certain TLD applications to include a letter of non-objection or support from the applicable geographic government the applied-for string corresponds with, these applicants have had to demonstrate their goal of service the public interest in order to gain government support, whereas IDN domain names are prioritized merely on the basis of not (or not purely) using latin characters. With their more regional outreach, geoTLDs create a local identifier for a regionally defined community and the public interest of the served community, be it small like the Saarland region or large like the continent of Africa. Furthermore, the .CAT TLD that serves the Catalan community already demonstrates how geoTLDs may serve the public interest.

The small number of geographic TLD applications with governmental support would at the same time ensure that the remaining non-prioritized applications would not be unduly delayed. In other words, prioritization of geoTLDs would not have a significant negative impact on other applicants, but a substantial public benefit.

We therefore respectfully propose to either include TLD applications designated as geographic and in possession of proper government approval with the IDN applications at the top of the queue, or to at least create a second tier of prioritizations for geoTLDs after the IDNs but prior to the remaining applications.


Should you have any further questions, please do not hesitate to contact us.

Best regards,

Volker A. Greimann

Key-Systems GmbH

Member of the KEYDRIVE GROUP

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