dotEUS Foundation (.EUS, Basque Language and Culture Community)

["Iratxe Esnaola Arribillaga | PuntuEus Elkartea" <info@xxxxxxxxxxxx>]

This comment by PuntuEUS Fundazioa (dotEUS Foundation, applied for .EUS, a
new gTLD for the Basque Language and Culture Community) seeks to respond to
the request for comments on the Use of a Drawing for Prioritizing New gTLD
Applications.

 PuntuEUS Fundazioa does believe in the need of a deep and real debate
about the meaning of 'Public Interest' and 'cultural diversity' concepts
within the new gTLD process and the corresponding criteria for establishing
priorities for approving and launching new gTLDs. However, we are aware of
the delay this debate could cause, but we do consider that this debate
would ensure more fair prioritization criteria.

 That's why we discarded Digital Archery and we are against the Draw. They
are different one from each other, but both are unfair. There are lots of
reasons for being against the Draw, but these two are the main ones for us:


   1.

   It's a method that does not seek to respond to the objectives of Icann
   in general, and the new gTLD process in particular. Quite the opposite: it
   goes against them. or... does the Draw foster 'cultural diversity' and
   'public interest' on the Internet?
   2.

   It's a method that does not respond to the need of a deep debate about
   how to define some criteria to establish prioritization in the approving
   and launching of new gTLDs. It does not provide new criteria apart from the
   one that was defended in Digital Archery for IDNs. We agree on prioritizing
   IDNs, but apart from IDNs... are all new gTLDs equal? Are there some new
   gTLDs which are similar and that should be approved and launched at the
   same time?

 During the new gTLD process, the meeting hold in Toronto and during this
comment period, some ideas have been presented in order to make the use of
a Draw for Prioritizing more fair. These that we quote below are some of
the issues that PuntuEus Fundazioa considers essential:


   1.

   GAC Communiqué (October 17th, 2012): referring to the request for
   prioritizing community-based new gTLDs, new gTLDs from developing countries
   and geoTLDs that got the support of their relevant government. This is, in
   our opinion, the best way to defend 'public interest' and 'cultural
   diversity' on the Internet.
   2.

   Applicant should have the opportunity to indicate with which TLDs wish
   to be tied, having the same draw number. If this issue is not respected,
   the use of a Draw for Prioritizing may create dramatic scenarios, such as
   approving and launching two different linguistic and cultural new gTLDs of
   a given State, one in july 2013 and the other one, one year later. This
   scenario would impact drastically, directly and negatively on the launching
   of the second one. This is the best way to group those gTLDs that want to
   be approved at the same time, as the applicants are the ones that best know
   which are their objectives and with whom they should be launched. It's an
   idea that does not change the idea of using a Draw, because it is focused
   on the method, not in the tool. That's why applicants should have the
   opportunity to express this desire.