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Proper execution of EOI is required to make it predictive of future applications

  • To: eoi-new-gtlds@xxxxxxxxx
  • Subject: Proper execution of EOI is required to make it predictive of future applications
  • From: Andrew Allemann <editor@xxxxxxxxxxxxxxxxxx>
  • Date: Thu, 12 Nov 2009 09:48:07 -0600

I like the idea of "Expressions of Interest" for new top level domain
names.  If properly implemented, it will give us an idea of the scale and
complexity we're dealing with for new TLDs.  It will also help us understand
particular string contention issues that may not have been anticipated in
the Draft Applicant Guidebook (DAG), or at least provide specific examples
to debate.  I wish to comment on a few aspects of the idea:

1.  There must be an incentive for companies to participate.  My preferred
incentive is to require companies to participate in the EOI if they want to
apply for the TLD.  Otherwise, the EOI will not provide an accurate estimate
of interest.

2. There must be a penalty for companies that don't follow through with
applying for the TLD that they submit an EOI for.  My preferred penalty is
to require a steep, non-refundable fee to submit an EOI.  I understand that
some companies may be wary to pay a significant amount when there is no
guarantee that new TLDs will go forward.  That's a risk they might just have
to take.

The fee should be per TLD applied for; otherwise one applicant may file for
a number of TLDs to "scare off" competition.

3. ICANN should understand that the level of applications under EOI does not
indicate economic demand for new TLDs from registrants.  It only indicates a
level of demand from entrepreneurs wishing to release new TLDs.

A number of people have called for the economic studies on new TLDs to be
carried out.  But let's be honest, we can look at previous new TLD rounds to
see the level of demand for new TLDs.  It's relatively low.  I'd rather
ICANN not waste any more money paying an economics professor to write
"whitewash" reports on the economic demand and benefits for new TLDs.

4. With regards to the question on if a company can get a refund if the DAG
changes, this is a tough question.  There must be some level of significant
change to allow a company to back out, and it must be clearly defined.
Otherwise there will be a loophole which will negate the entire benefit of
the EOI.  Again, this is a risk companies will just have to take.  Everyone
entering the ICANN process for new TLDs knew there as risk it would either
be significantly delayed or may never happen, so it's just part of the risk

Best regards,
Andrew Allemann

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