dotHotel | Comments on 'Expressions of Interest in New gTLDs' Proposal

[Johannes Lenz-Hawliczek | HOTEL Top-Level-Domain GmbH <johannes@xxxxxxxxxxx>]

I would like to thank the ICANN Board for its decision to study the
potential impact of a call for formal "Expressions of Interest" and to
ask ICANN staff to develop a plan for this process. As a member of the
EOI Working Group I fully support the proposal which has been
developed by the group and I appreciate the opportunity to comment on
the specific issues which are posted on
http://icann.org/en/public-comment/#eoi-new-gtlds.

To 1: Accurate representation can be ensured by making the
participation in the EOI process mandatory and attach a serious fee to
it.

To 2: Definitely yes. There must be a strong incentive besides a fee
for those potential applicants who are not public today and to thus
generate data with which ICANN can work.

To 3: Again definitely yes. If there is no substantial deposit, anyone
can claim that he intends to apply for any string without any
consequences. This would result in unreliable data since the
seriousness of such an EOI would not be substantiated with a financial
commitment.

To 4: A refund should be given in the event of the actual application.
The deposit should then be deducted from the proposed application fee
of USD 185,000. Apart from this, a refund scheme should be created
that correlates with the time passed between the date of the original
EOI and the actual application. If for instance no application window
has opened after 12 months after placing the EOI, a full refund should
be possible at the request of the applicant. This way it could be
avoided that potential applicants loose even more of their money in a
process without a foreseeable end.

To 5.1: Applicants organization / Applicants contact data / String(s)
to apply for (including IDN) / Expected number of domains per
string(s) applied for / Special registry services planned for the
string(s) applied for

To 5.2: Yes. In any case the combination of applicant’s organization
and string(s) is required to help negotiate settlements between
applicants.

To 5.3: Yes.

To 6: Yes, otherwise the process is not in alignment with the
proposals of the DAG.

To 7: It is desirable that at the time of filing the EOI there is a
version of the DAG which contains agreed upon sections that should not
be changed after the EOI.

To 8: We don’t see any serious risks in this proposal and that its
benefits outweigh them by far. There is no risk for ICANN which
benefits most from the data which will be generated by the process.
There may be a risk for applicants for contented strings and for
generic brand names who do not want to publish their plans at this
point in time.

Sincerely

Johannes



Johannes Lenz-Hawliczek
Partner

HOTEL Top-Level-Domain GmbH
Akazienstrasse 2
10823 Berlin / Germany
Tel: +49 30 4980 2721
Fax: +49 30 4980 2725
johannes@xxxxxxxxxxx
www.dothotel.com