DotSport comments on the expression of Interest Proposal

["Anne Deschuyteneer -.sport registry" <anne@xxxxxxxxxxxxx>]

The DotSport Registry, a not-for-profit organization, thanks ICANN for the
opportunity to comment on the Expression of Interest proposal.

We have been closely working within the bottom-up working group that
submitted a report earlier on, and support it.

Please allow us to detail our positions on the following questions:

1.  How do we ensure that participation in the EOI accurately represents
the level of interest?

In order to achieve that goal, we think that a deposit should be expected
from applicants in order to demonstrate they seriously intend to submit an
application for a new gTLD.
   
2. Should only those who participate in the EOI be eligible to participate
in the first round when the program officially launches?
   
Obviously, yes. If it was only an optional step, there would be no way to
assert the volume of applications. Participation in the EOI process should
be a pre-requisite for filing an application later on. 

3. Should a deposit be required for participation in the EOI?

Yes. A significant deposit will help eliminate frivolous applications. At
the same time, the deposit should not be a major barrier of entry for those
serious applicants who are not yet well-funded. One of the goals of this
process is to allow potential applicants to seek financial support from
their community. 

Keeping in mind the different sizes and business models the applicants
will pursue, we suggest that a deposit of $25,000 would allow
not-for-profits and applicants from less favoured countries to submit their
expression of interest. 

That deposit would then be deducted from the application fee later on,
should the EOI participant choose to go ahead with his application. 
   
4. If there is a fee, under what circumstances should there be refund?

Unless there are major changes in the criteria between the current draft
at the time of the EOI launch and the final RFP, there would be no reason
to refund applicants.

5. What information should be collected from EOI participants?

Applicant's organization  and contact data. String  applied for (including
IDN)

* 5.3  Should information be made public?

Yes. Especially in case of string contention, the goal is to allow
competing applications to settle an agreement ahead of the application
process, thereby limiting the number of auctions.

6. Must the responder commit to go live within a certain time of
delegation?

Yes. We think though that this is irrelevant in the framework of the EOI,
but should be part of the final RFP. 

7. What are the implications for potential changes to the Applicant
Guidebook after the EOI participation period closes?

As mentioned under question 4 above, there should be a very limited set of
changes to the AG after the EOI participation closes. Applicants should
have a good level of certainty that the evaluation criteria will not
fundamentally change after the EOI is open. This is especially critical for
community-based applications, where criteria are possibly still subject to
changes in a major way.    

8. What are the potential risks associated with the EOI?

We have not be able to identify any risk related to the EOI process. We
think in any case that the benefit of such process largely outweighs any
risk.


Anne Deschuyteneer
Eexcutive Director - DotSport registry

DotSport Registry
66 rue de Luxembourg
L-4221 Esch-sur-Alzette
G.D. Luxembourg

E-Mail   anne@xxxxxxxxxxxxx
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