Response from DotEco on the new EOI proposed process.

[Fred Krueger <frkrueger@xxxxxxx>]

Who we are: Dot Eco LLC, is an entity supported by the Sierra Club,  
the World's oldest and largest Ecological Organization, and Al Gore,  
recipient of the 2007 Nobel Peace Prize for his work on promoting  
climate change.
In response to the specific questions posed by ICANN staff regarding  
the EOI process:
1 / 2 /3. Insurance that the EOI truly represents the level of interest.

Anyone can claim an interest for anything. However, by requiring a non- 
refundable deposit of $50,000 as well as making the EOI mandatory,  
only serious applicants will apply. Obviously, the number of  
applicants will still only represent a tight upper bound on the  
ultimate application level, however we do not think, in this economy,  
that many participants will easily risk these high fees frivolously.
It is obviously CRITICAL that only those participate in the EOI be  
allowed to participate in the round. If the EOI is optional, no one  
will participate, nor benefit from the process.
It is also CRITICAL that the EOI have a significant price tag. At the  
full price of $185,000, the EOI will more directly correspond with the  
exact number of applications. At a lower price, (say $50,000), the EOI  
application process will overestimate the total number of  
applications; however, it will still provide an upper bound, and the  
ultimate number might still be inferable from the data.
4. Refunds

Refunds must be at ICANN's sole discretion, unless the entire  
application process is abandoned -- say by Dec 31, 2010. The EOI  
process needs to be a serious commitment on the part of the applicants.
5. Information collected

The information collected should be a succinct as possible. Ideally,  
we should limit this to the string applied for, the name applying  
entity, and the contact information. Any other information can be  
collected from ICANN post-fact. This should not be a shorter version  
of the DAG.
Public disclosure of the information is necessary. This will identify  
potential trademark abuse, enable economic studies, allow for early  
conflict resolution, and identify possibly public order and morality  
issues.
6. Go live commitment

This is erroneous. Any such commitment would involve a contractual  
relationship and a deepening of the EOI process that is counter- 
productive.
7. Potential changes to DAG

The only change is that the EOI would be a required perquisite to  
application. The full application fee would be reduced by the EOI fee.
8. Risks associated with EOI

The primary benefit of the EOI is to to reduce risk: risk of  
inaccurate economic studies, risk of uncertain timelines, root scaling  
risk, trademark violation risk, geographic nation interest risk,  
public order risk, risk of the unknown.
Once the universe of strings has been established, these risks can be  
contained and understood.
On the negative side, the EOI might cause further delays in the  
ultimate process. As participants we are prepared to accept that risk  
in order to maintain the integrity of the Internet, ICANN and the  
process,
Fred Krueger and Minor Childers.