Comment from the GeoTLDs Applicant Group

["[GeoTLDs] - Dirk Krischenowski" <krischenowski@xxxxxxxxxxxx>]

This is a joint statement emanating from a majority of applicants for a 
“Geographical Name Top Level Domain” (GeoTLDs) including .广东, ابوظبي. , 
..abudhabi, .africa, .alsace, .amsterdam, aquitaine, .barcelona, .bayern, 
.berlin, .brussels, .boston, .capetown, .catalonia, .cologne, .dubai, .durban, 
.frl, .gent, .hamburg, .joburg, .koeln, .london, .madrid, .melbourne, .москва, 
.moscow, .nrw, .osaka, .quebec, .rio, .paris, .saarland, .sydney, .tirol, 
.vegas, .vlaanderen, .wien.

ICANN has received 63 applications for unique strings from all ICANN regions 
that declared themselves to be GeoTLDs in their application. 7 GeoTLD 
applications are IDNs. 11 GeoTLD applications are filed as community-based. All 
three designations (IDN, Geographical Name, Community-based) have been 
integrated in the Applicant Guidebook to protect the legitimate interests of 
the Global Public Interest in strings concerned.

Each of the GeoTLD applications has to have the support or non-objection of the 
respective government(s) or public authorities before approval by ICANN; some 
GeoTLDs have even been filed by public authorities themselves. 

The requirement for government support or non-objection is a core element of 
the GAC Principles Regarding New gTLDs issued in March, 2007. These public 
policy principles were introduced to safeguard the global public interest! 

Principle 2.2 says: "ICANN should avoid country, territory or place names, and 
country, territory or regional language or people descriptions, unless in 
agreement with relevant governments or public authorities.

In this way GeoTLDs complement the provisioning of ccTLDs, we are in the 
interest of the relevant national and global Internet community on a focused 
local basis. 

With this background we are convinced that the GeoTLD applications fulfill the 
requirements set by ICANN to give a priority to certain categories of TLDs: to 
promote DNS diversity, make the Internet more accessible, increase avenues of 
participation and serve the public interest.

The above-mentioned arguments have been echoed and strengthened by concerned 
GAC members during their Toronto meeting and in the GAC communique as well.

We have noticed the intention of ICANN to award a prioritization for IDN TLD’s 
that would allow them to become first in line for the process starting with the 
initial evaluation and ending with the string being added to the root. We fully 
understand the arguments that ICANN has invoked for its intention with the IDN 
TLDs but we would ask the ICANN leadership to consider exactly the same 
arguments in view of the applications for geographical TLDs. It is our strong 
belief that global diversity, accessibility and participation, as well as 
public interest are best met by awarding an equal prioritization to GeoTLD 
applications. Besides the core values mentioned previously, there are also 
other arguments in play that would justify a prioritization for GeoTLDs. 

The prioritization of the remaining 56 GeoTLDs would adjourn the allocation of 
other generic TLDs only for about 2-3 weeks. We think this is a reasonable time 
to protect the global public interest. 

Additionally in terms of public interest there would be much more sense to 
launch .МОСКВА (IDN version of .MOSCOW) simultaneously with the ASCII version 
.MOSCOW, not up to 1,5 years ahead as it could happen in case only IDNs are 
prioritized. The same applies for .ABUDHABI and its Arabic IDN version ابوظبي. 
Neither does it make sense that .COLOGNE (English translation of the city gTLD 
.KOELN) and .KOELN should launch months apart from each other depending on the 
DRAW ticket number.

We think that the prioritization of the GeoTLDs along with the IDN gTLDs would 
better serve the global public interest ICANN represents. The explicit support 
these applications have from their respective public authorities, the entities 
entitled at the local level to serve and promote the public interest, should be 
taken into consideration by ICANN in order to promote an alignment between the 
local and global public interest spheres.

We would like to thank the ICANN leadership and staff for taking our comments 
into consideration and are looking forward to work with you in getting our 
GeoTLDs through the various stages of the new gTLD program.