Travelers Comment on New gTLD Prioritization Drawing

["Winterfeldt, Brian" <bwinterfeldt@xxxxxxxxxxx>]

Dear Mr. Pritz:

Steptoe & Johnson LLP submits this comment on behalf of its client The 
Travelers Companies, Inc.

An Applicant Should Be Permitted To Allocate Its Draw Numbers Among Its Own 
Applications at Applicant's Discretion

The prioritization draw method provides that "draw numbers cannot be exchanged 
between applications or applicants."  We suggest that applicants be allowed to 
allocate their tickets among their own applications based on the applicant's 
business priorities.  This allows an applicant that has several applications 
pending to select the order of priority among the applicant's tickets based on 
the draw numbers obtained by that applicant.

If for some reason, ICANN does not allow swapping between applicants, we still 
propose adoption of the above recommendation.

Thank you,

Brian

Brian J. Winterfeldt
Partner
bwinterfeldt@xxxxxxxxxxx<mailto:bwinterfeldt@xxxxxxxxxxx>
Steptoe

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