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

  • To: eoi-new-gtlds@xxxxxxxxx
  • Subject: Fwd: On estimates of applications arising from any "EOI" and zone file access
  • From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
  • Date: Mon, 28 Dec 2009 16:23:04 -0500

This is a resend, as the original, sent at 10:08am EST, and confirmed at 10:09am EST, hasn't resulted in the comment being posted.

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


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

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

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

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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