Comments from CRONON AG on the TMCH "Strawman" proposals

["Michael Shohat, Cronon AG" <mshohat@xxxxxxxxxx>]

Dear ICANN staff,

CRONON AG is a European registrar of ccTLDs and gTLDs. We appreciate the
opportunity to comment on this topic.

We oppose both the proposals themselves and the process by which
they were introduced. We thus strongly support the comment submitted by
the Registrar Stakeholder Group (RrSG).

It is alarming that important policy matters on which community
agreement has long been reached after much public debate, are once again
opened for discussion in a non-public limited forum, and its proposals
even seriously considered at the last minute.

Regarding the content of the proposals, we consider them mostly harmful
for large parts of the community, on the grounds detailed in the RrSG
comments.

Adoption of the proposals would lead us as a registrar to
seriously reconsider whether offering new gTLDs is such a good idea
after all. The more additional hassle is required from registrants to
satisfy the demands of a narrow group of stake holders, the less
probable the broad adaptation of new gTLDs becomes.

We've already experienced certain ccTLDs shooting themselves in the foot
with politically motivated restrictions or bending technical systems
over backwards to include questionable requirements, and we would like
to avoid such adventures in the future.

We urge you to consider carefully the implications of the proposed
policy changes for the entire community, as detailed in the RrSG
comments, and are confident that in this matter, as in the past, ICANN
will respect the multi-stakeholder path.

Kind regards,
Michael Shohat


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Dr. Michael Shohat
Head of Registrar Services
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fon: +49 30 39802-0
fax: +49 30 39802-222
website: www.cronon.net
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Cronon AG
Professional IT-Services
Pascalstraße 10
D-10587 Berlin
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County Court: Berlin-Charlottenburg HRB 77957