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On estimates of applications arising from any "EOI" and zone file access

  • To: eoi-new-gtlds@xxxxxxxxx
  • Subject: On estimates of applications arising from any "EOI" and zone file access
  • From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
  • Date: Mon, 28 Dec 2009 10:08:50 -0500


In the November 24th briefing paper on zone file access [1], there is a turn of phrase that is also surprising.

The Issue section, paragraph 2, begins thus:

"The ICANN process to expand the namespace to tens or perhaps hundreds of new gTLD could result in scaling challenges for interested parties to continue to collect and compile gTLD zone files for legitimate purposes."

I draw your attention to "tens or perhaps hundreds."

The briefing paper speaks to zone files, a consequence of delegations, and their access.

It anticipates a numeric range consistent with my earlier comments "the rate of change of the IANA root is a limited resource, and the limit per year or recurring application period is about half of the number of entries of the IANA root at present" at [2].

The purpose of my comment, not accurately captured in the issue summary at [3], was to point out that, independent of all other issues, if the rate of change is the limiting resource, that other "data", which the proposed EOI model is intended to acquire, is decorative, not informative.

Of course, this was not the majority view, and in a technically informed, bottoms-up, multi-stakeholder, consensus-based private organization, it is reasonable for broadly held policy goals to only be critically re-examined when they cannot be realized with available mechanisms.

The Draft Expressions of Interest/Pre-Registrations Model [4] continues to anticipate a volume of applications several multiples of, if not an order of magnitude greater than, the range of anticipated delegations in the briefing paper on Zone File Access.

How are these two anticipations of volumes to be reconciled?

Should we assume that as many as nine out of ten applications by city governments, regional governments, and cultural and/or linguistic institutions, using the best application of record, CORE's 2004 sTLD application on behalf of PuntCAT, as modified to reflect the requirements in the DAGvX, will fail to result in delegations?

Should we assume that as many as nine out of ten applications for "generic" strings will fail due to string contention, and possibly defects in their applications, or other reasons?

Should we assume that applications will not fail at a nine out of ten rate, but that the number of non-failed applications will be significantly greater than the number of delegations?

I'm sure there are other possible means to reconcile the Zone File Access briefing paper and the Draft Expressions of Interest/Pre-Registrations Model paper. Even typographical error is possible.

As in my two prior comments, I'm not trying to re-argue that the EOI can't be useful, I've already made that case, and I'm pleased that Staff's summary of comments caught the more obvious points I made. I'm also not trying to argue for any particular form internal to the EOI model. I'll turn to that later, or my colleges at CORE will.

My sole interest is in the Staff's statements of anticipated volumes, of applications, and of zone file access agreements.

I am of course, employed by CORE, which has an interest in the outcome, though as usual, this is offered in my individual capacity.


[1] Zone File Access and HSTLD Briefs 091124 v2.doc, attachment to Request for volunteers for Expert Advisory Groups, email to various GNSO Stakeholders, received 27 November.

[2] http://forum.icann.org/lists/eoi-new-gtlds/msg00067.html

[3] http://www.icann.org/en/topics/new-gtlds/eoi-model-18dec09-en.pdf
At page 5, reads

In addition, some comments indicate that
an analysis of available market capital indicates that demand will not exceed 
500 applications.
Therefore, according to the comment, the EOI process will not provide data to 
resolve demand and root
scaling issues beyond that which is already known. Therefore the EOI cannot 
serve any useful
quantitative purpose, i.e., the EOI is not necessary for ICANN to address 
root‐scaling concerns.

There was no mention of "market capital" in my comment, only of the marketing (public awareness) campaign ICANN has committed to since the new gTLD process began. The summary appears to have conflated two or more comments, one by a "market capital" informed commenter, and my technically informed comment.

[4] supra.

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