Nominet UK Comments on Proposals for Drawing for Prioritizing New gTLD Applications

[David Abrahams <David.Abrahams@xxxxxxxxxxxxxx>]

Sent on behalf of Alex Blowers, Director Of Legal & Policy, Nominet UK

NOMINET COMMENTS ON PROPOSALS FOR USE OF A DRAWING FOR PRIORITIZING NEW gTLD 
APPLICATIONS

Nominet has applied to become the registry of two new gTLDs - .CYMRU and 
.WALES. These gTLDs are intended to provide a space on the Internet for the 
people and businesses of Wales, a constituent country of the UK, and those 
people and businesses who wish to address a Welsh audience. Nominet will 
operate these domains for the public benefit and on a not-for-profit basis. Any 
surplus generated by the operation of the registries will be donated to a 
charitable vehicle with a remit to benefit Welsh society.

The two TLDs reflect the name of the country in both of its official languages; 
Welsh and English. While the two registries are to be separate, they will be 
linked through identical administrative policies and the way they are used by 
registrants. The two domains will allow consumers and businesses to express 
their identity and pride in whichever language they choose.

Nominet is committed to launching these two domains at the same time. To launch 
separately risks excluding those members of the Welsh community who may prefer 
to use either Welsh or English. Furthermore, it is a legal requirement within 
Wales for public bodies to give equal treatment to both Welsh and English.

As the two applications are, in all material respects, identical, and they will 
be run and maintained on the same systems maintained by Nominet, we believe 
that all pre-delegation matters can be dealt with in parallel in order to 
facilitate a concurrent launch.

In light of the above, we have several comments to make on the proposed use of 
a draw to prioritise new gTLD applications.

GEOGRAPHIC APPLICATIONS

As has already been raised in correspondence with the ICANN executive by a 
number of applicants and interested parties, we do not believe that appropriate 
priority has been given to geographic applications that are being operated for 
the public benefit.

There are 66 geographic applications for new gTLDs (including some apparent 
contention sets) and under the current proposal they will be treated in the 
same way as community, brand and generic applications in the draw. This 
contrasts with the treatment of IDN applications in the proposed prioritisation 
mechanism, as they are guaranteed to occupy the first 116 draw slots.  Whilst 
we recognise the arguments for IDNs receiving priority treatment, the reality 
is that many of those 116 applications are purely commercial in character and 
do not have either the demonstrated public purpose  or the explicit stakeholder 
endorsement of our Wales/Cymru applications.

Our view is that geographic TLD applications, operating for the public purpose, 
fulfil a very similar role to that which has been claimed for IDN TLD 
applications, furthering ICANN's international outreach strategy by providing 
an online space for underrepresented or excluded groups internationally. 
Therefore Whilst we accept that IDNs should be given top priority, we submit 
that geographic TLDs should also be prioritised by being allocated the 66 draw 
slots subsequent to the 116 IDN draw slots.

LINKED APPLICATIONS

As set out above, Nominet is in the unusual position of having two closely 
linked geographic gTLD applications. Given the political and practical 
considerations, we would ask that you give consideration to a mechanism whereby 
we can link the two applications so that they can go through pre-delegation 
testing and delegation at the same time.



David Abrahams
Head of Public Policy
Nominet