RE: [gnso-idng] rethinking IDN gTLDs

["Gomes, Chuck" <cgomes@xxxxxxxxxxxx>]

Eric,

As I know you understand, even if there are no direct costs to
applicants for the failure you cite, the bottom line is that the
application fees could be lower if the evaluation process was less
expensive.

Chuck 

> -----Original Message-----
> From: Eric Brunner-Williams [mailto:ebw@xxxxxxxxxxxxxxxxxxxx] 
> Sent: Monday, November 30, 2009 5:03 PM
> To: Gomes, Chuck
> Cc: Avri Doria; gnso-idng@xxxxxxxxx
> Subject: Re: [gnso-idng] rethinking IDN gTLDs
> 
> Gomes, Chuck wrote:
> > I suspect we have gotton off topic for this list but it is an 
> > interesting discussion that I continue below.
> 
> ...
> 
> 
> > On a side question: is there such a thing as a non-monetary cost, 
> > especially with regard to the proposed new gTLD process?
> 
> That is the case I tried to convey below. The cost is 
> non-monetary, because the result is not greater cost to 
> applicants, or to evaluator, but failure after the 
> non-disclosed capability inter-dependency is tested during 
> live operations.
> 
> 
> >> Suppose Fly-by-Nite-Registry-Wannabie-LLC (FbNRW-LLC) submits an 
> >> application for R1. Upon evaluation, FbNRW-LLC is just 
> barely capable 
> >> of operating R1. However, FbNRW-LLC has also submitted 
> applications 
> >> for R2, R3, ... all of which have the same evaluation 
> results. Just 
> >> barely qualified.
> >>
> >> The only way the current process allows this information 
> to be known, 
> >> by anyone other than FbNRW-LLC, is when FbNRW-LLC fails to operate 
> >> one or more, even all of R1 or R2 or R3 or ... When they 
> don't meet 
> >> their performance numbers.
> 
> Charging more, or less, doesn't cause FbNRW-LLC to disclose 
> that it has applied for more registry authorizations than it 
> can operate. The failure of the evaluation process to detect 
> the multiple applications by FbNRW-LLC and to sum up the 
> technical obligations (however nominal that activity may turn 
> out to be) creates a cost outside of the evaluation process, 
> after that process has concluded.
> 
> The KPMG guy, and apparently ICANN staff, don't see anything 
> wrong with each application being evaluated with no external 
> knowledge. My point was, as yours was, that this creates 
> avoidable cost, and obscures detectable failure.
> 
> Eric
>