Neustar Comment on Joint SO/AC Working Group on New gTLD Applicant Support Snapshot

["Neuman, Jeff" <Jeff.Neuman@xxxxxxxxxx>]

Neustar wishes to express its support for the effort by the Joint SO/AC Working 
Group on New gTLD Applicant Support (JAS-WG) to develop a sustainable approach 
to evaluate and propose recommendations for providing support to applicants 
requiring assistance in applying for and operating new gTLDs.  Neustar agrees 
that, in some limited circumstances special consideration should be given to 
Applicants proposing certain types of gTLDs, who otherwise would not have the 
financial means or access to resources or expertise required to participate.

The JAS-WG in its current draft document, presents an analysis of the costs 
associated with application fees, and makes a number of very practical 
recommendations that would reduce the cost of participation.  Given the very 
limited number of Applicants who would be eligible under the proposed criteria, 
the costs savings outlined would not seem to have a significant impact on the 
overall funding for new gTLDs, while opening the process to some Applicants who 
would otherwise not be able to participate.  Neustar is particularly supportive 
of the staggered fee approach recommended by the WG, and the use of some 
portion of any auction proceeds to provide a partial refund of application fees 
to qualified applicants.   Since the minimum annual fee of $25,000 would likely 
be very challenging for some disadvantaged Applicants, Neustar also supports 
the elimination or reduction of fees for disadvantaged applicants, but only in 
circumstances where registration volumes do not support payment of the annual 
minimum.

The qualifications identified by the JS-WAG document appropriately targets 
ethnic and linguistic communities in the initial/pilot phase while providing 
preference to applicants geographically located in Emerging Markets/Developing 
countries and in languages whose presence on the web is limited.  The document 
also presents appropriate criteria for determining who would not qualify for 
special support.  Some additional thought should be given, however, to the 
evaluation process for those Applicants who wish to participate, including the 
timing and resources required.  The transparency of the process, including 
information about the Applicants, the details of the program applications, as 
well as financial or other support received is particularly important to foster 
confidence in the program.

It is Neustar's intention to participate in the program by providing support of 
some kind to qualified Applicants.  We look forward to future progress, and 
wish to express its thanks the members of the JAS-WG for the excellent work 
completed to date, for what is a very good cause.
Jeffrey J. Neuman
Neustar, Inc. / Vice President, Law & Policy
46000 Center Oak Plaza Sterling, VA 20166
Office: +1.571.434.5772  Mobile: +1.202.549.5079  Fax: +1.703.738.7965 / 
jeff.neuman@xxxxxxxxxxx<mailto:jeff.neuman@xxxxxxxxxxx>  / 
www.neustar.biz<http://www.neustar.biz/>
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