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Questions to propose to clarify new stld selection criteria.htm
  • To: <stld-rfp-comments@xxxxxxxxx>
  • Subject: Questions to propose to clarify new stld selection criteria.htm
  • From: "George Nagel" <gnagel@xxxxxxxxxxxxxxxx>
  • Date: Fri, 16 May 2003 17:58:28 +0200
  • Importance: Normal
  • Reply-to: <gnagel@xxxxxxxxxxxxxxxx>


The following comments are made on behalf of AllGlobalNames, an
ICANN-accredited registrar, in response to the consultation paper entitled
  "Criteria to Be Used in the Selection of New Sponsored TLDs".

  Kind Regards,

  George Nagel
  AllGlobalNames
  gnagel@cyberegistro.com
  --------------------------------------------------------------------------
---
  (See attached file: stldcomments.html)




Title: Questions to propose to clarify new stld selection criteria

To Whom it May Concern,

 

 

 

The following comments are made on behalf of AllGlobalNames, an ICANN-accredited registrar in response to the consultation paper entitled "Criteria to Be Used in the Selection of New Sponsored TLDs" (the proposal).  First, we would like to express our appreciation for the opportunity to comment and also express our support for the process of expanding the number of gTLDs. As requested we restrict our comments to the proposal but we would like to take the opportunity to strongly support that:

 

a) The DNS be further expanded beyond the current proposal of adding a limited number of sponsored TLDs, with sponsored as well as unsponsored TLDs; chartered as well as unchartered TLDs; open as well as closed TLDs; generic as well as specific TLDs.

 

b) For this and the successive rounds of TLDs, the focus should be on the usefulness to a given community of a given TLD, provided that it abides with ICANN policies and does not destabilize the DNS. The proposal, in general, over stresses the risks of non-complying names being registered while overlooking the even more legitimate goal of providing useful and meaningful TLDs and names for any given Internet community of users.

 

c) More concretely, applicants should not be required to ensure that some things will not happen, as such a proof is, in itself,  impossible. Reasonable policies and sensible compliance mechanisms should be the focus, not the impossibility of by-passing the mechanisms.

 

In addition, we would like to present the following concrete comments on the proposal:

1. In section 2(d) Commitment to ICANN policies states that the “Proposing sponsor must indicate commitment to abide by all applicable ICANN policies.”

Why assign 5 points if the proposed sponsor is required to indicate that it will abideand just that??

2. It appears that the evaluators will be assessing the same criteria in 2 different areas of the application. 

The first instance is in section 3a(ii) “Proposed name represents an endeavour or activity that has importance across multiple geographic regions”

The second instance is in section 4(b) Global reach and accessibility (8) “gTLDs are intended to serve broad global communities. (i) Global distribution of communities served”

Why evaluate the same criteria twice? Isn’t this  double jeopardy?

3.  In section 4,  How can you prove community support? What should be provided to prove “Evidence of community support for the proposed sTLD”

4. Section 5(a) Ensure that only charter-compliant persons may obtain registrations, states “Operators of sponsored TLDs are expected to implement safeguards to ensure that non-compliant applicants can not register domain names.

(i) Mechanisms to filter non-compliant applications

(ii) Actions to be taken if non-compliant registrations occur”

Are both (i) and (ii) required? In other words: Shouldn’t applicants get the chance to opt for ex-ante and/or ex-post compliance mechanisms?

5. Section 6  Provide complete and well-structured proposal (20) states that “Proposals must be complete in responding to the criteria requirements and in providing other required information. Proposals must also be well-structured to allow for ease of evaluation.”

How do you define “well structured” to allow for ease of evaluation?  In addition, how do you define “not well structured”?

6.  We understand that the applicant will have an opportunity to respond to the evaluators.

How will this be structured? How much time will be allotted? Will applicants be able to clarify evaluator questions? What kind of dialog can applicants expect?

7.  In section 2 (b) it is stated that "the sTLD sponsoring organization should be a not-for-profit membership organization, with a clear charter that defines permissible registrants and provides for appropriate participation of the affected community which may be broader than the class of potential registrants in the formulation of policies for the sTLD."

In our view, the focus should be on a not-for-profit organization that is controlled with clear mechanisms by the relevant community of users to which the TLD is offered in general, and with defined participation of the registrants in particular. Ability to elect and control the managing bodies, the budget and active participation in establishing the policies should be the driving point. The legal form should be less relevant. For instance, a foundation is not technically a membership organization, as it cannot have statutory members, but seems to be a perfectly appropriate legal form for the sponsoring organisation. This is particularly true in certain legal orders where it is difficult to set up associations, or other membership organisations, combining both legal and natural persons in the same structure.

Kind Regards,

 

George Nagel

AllGlobalNames

gnagel@cyberegistro.com


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