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Response from DotEco on the new EOI proposed process.

  • To: eoi-new-gtlds@xxxxxxxxx
  • Subject: Response from DotEco on the new EOI proposed process.
  • From: Fred Krueger <frkrueger@xxxxxxx>
  • Date: Wed, 11 Nov 2009 16:42:56 -0800

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.

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