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Expression of Interest Comment

  • To: <eoi-new-gtlds@xxxxxxxxx>
  • Subject: Expression of Interest Comment
  • From: "Thomas Lowenhaupt" <toml@xxxxxxxxxxxxxxxxx>
  • Date: Fri, 27 Nov 2009 19:48:16 -0500

My ICANN involvement is in two areas: as an observer and occasional participant 
of its governance processes, and as an advocate for the development of the .nyc 
TLD as a public interest resource serving the residents and organizations in 
New York City. My EoI comments address both of these areas.


In the notice about the EoI, ICANN provided the following timing and process 

"The public comment forum will be open until December 11, 2009 however, 
community members that wish to have their input considered by the Board during 
its December meeting, should submit comments no later than November 27, 2009." 

I attended the Seoul meeting and watched and suffered with everyone else as new 
TLD process delays were announced. So the desire to keep the process moving 
through the EoI is understandable. But I register my disapproval of shortening 
the effective submission time by two weeks. Good governance benefits from 


As to the EoI, my perspective is that of a one focused on the .nyc TLD and more 
broadly, city TLDs. 


An earlier commenter on the EoI referenced the difficulty of getting a $55,000 
check for a speculative investment of this sort from a large corporation. 
Having participated in city government for many years, I know that the 
difficulty there is far more complex and time consuming. It will be extremely 
difficult for cities to express their interest if a fee is required. 


In the instance of the city of New York, I suggest that its issuance of an RFP 
on October 5th for a partner to assist it with the acquisition and development 
of the .nyc TLD should suffice as its expression of interest. Perhaps other 
cities my express their qualifying interest in similar fashion. However, the 
following conversation shadowed negatively on this prospect.

I am often consulted by cities with an interest in their TLDs. Recently I 
contacted a representative from one of them to discuss the EoI process. She 
advised that it was extremely unlikely that her city would be able to 
participate in the EoI if it required a filing fee. And further, that decision 
making in her city was such that barring a finalized New TLD process and 
believable deadline for filing, that her city would not gear up for what she 
sees as a growing interest in a TLD. 


In the final moments of our discussion she asked about the consequence of an 
other than city entity filing an EoI for her city's TLD. Would her city's 
opportunity for an initial round filing then be controlled by that party? I 
said I'd pass on the question to ICANN.

Thomas Lowenhaupt

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