Nominet UK Comments on Proposals for Drawing for Prioritizing New gTLD Applications
- To: "drawing-prioritization@xxxxxxxxx" <drawing-prioritization@xxxxxxxxx>
- Subject: Nominet UK Comments on Proposals for Drawing for Prioritizing New gTLD Applications
- From: David Abrahams <David.Abrahams@xxxxxxxxxxxxxx>
- Date: Fri, 9 Nov 2012 18:24:40 +0000
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
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.
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.
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.
Head of Public Policy