Part III Q49: Does the
schedule allow sufficient time for formulation of proposals?
Yes, absolutely.
Q50:
Does the schedule allow sufficient time for public comment?
Yes, it does. The question
is only, if further comments are really needed instead of just starting to implement
new gtlds.
Q51: Should all proposals be posted for comment simultaneously to maintain
equal time for public comment? Should all proposals be posted for public comment
as they are received to allow the greatest possible time for public analysis and
comment?
Simultaneously.
Q52: Should the formal applications be posted in full
for public comment? If not, which parts of the applications should remain private?
Consider
keeping financial models private.
Q53: Should proposals choose a single proposed
TLD or numerous possibilities?
It might be worth while seeing how many registries
will apply. If there are engough registries, just give one TLD each.
Q54: Should
ICANN select the TLD labels, should they be proposed by the applicants for new TLD
registries, or should they be chosen by a consultative process between the applicants
and ICANN?
The TLD strings should be proposed by the applicants. ICANN should either
accept or reject the application.
Q55: Should there be minimum or maximum length
requirements for TLD codes? Are restrictions appropriate to avoid possible future
conflicts with ISO 3166-1 codes?
I see no reason to prescribe minimum or maximum
lengths. But if you want to reserve ISO-3166-1 country codes, which makes sense,
do not allow two-letter strings at all (cit. Dr. Mueller).
Q56: Should there be
restrictions on the types of TLD labels that are established (for example, a prohibition
of country names)?
I personally think it makes sense to allow country names. Even
if they may compete with cctlds they offer a lot of people another chance to register
their preferred name.
Q57: What should be the criteria for selecting between potential
TLD labels? Should non-English language TLD labels be favored?
No selecting criterias
are appropriate. Maybe registries could be urged to pay 10% of their earnings to
an account which will be used in case they get bankrupted after having sold out all
the good names.
Q58: How many new TLDs of each type should be included in the initial
introduction?
You asked this question already in Q20 and Q21: At least one fully
open TLD and 5 restricted TLDs.
There should be at least 6 new fully open TLDs
included in the initial introduction: .reg, .rcom, .rnet, .rorg, .web, .rweb. The
"r" standing for registered: Access only for registered trademark holders, as explained
under Q9. In my opinion, ".rcom" should be run by the .com registry, and so on ...
Q59:
Which types of TLDs will best serve the DNS?
"r"-tlds, see above, and open gtlds.
Q60:
Are there any types of TLDs that ICANN should not consider?
No.
Q61: Which types,
if any, are essential to the successful testing period?
"r"-tlds, see above, and
open gtlds. Allow me a question: Why do you need further testing?
Q62: Which other
structural factors, if any, should ICANN consider in determining the potential success
of a specific TLD proposal?
None.
Why should they all be successful?
Maybe
registries could be urged to pay 10% of their earnings to an account which will be
used in case they are not successful.
Q63: Should ICANN accept proposals from companies
formed/forming for the purpose of operating or sponsoring a new TLD? If so, how should
ICANN determine the competence of the company?
Yes, it should accept such proposals
and treat those companies like all the others.
Q66: How much capital should be
required? Should it be a fixed amount or should it vary with the type of proposal
and the sufficiency of the business plan? How should the sufficiency of capital be
evaluated?
The amount of capital required should vary depending on the type of
proposal and the business plan. Some of the "technical services" TLD proposals might
require significant technical expertise but generate little revenue; they would provide
support services for other revenue-producing activities. Some might be aimed at very
small markets or noncommercial constituencies. Others, such as a direct competitor
of dot com, might need to gear up for 35,000 registrations a day. (cit. Dr. Mueller)
Q67:
Should ICANN seek diversity in business models as well as TLD types? Which, if any,
business models are essential to a successful evaluation phase?
Yes, definitely.
It would be interesting to see whether an exclusive registry, which is much more
stable technically than a SRS, is constrained price-wise by the existence of other
competitors. (cit. Dr. Mueller)
Q68: What measures should be in place to protect
registrants from the possibility of a registry operator's business failure?
Registries
could be urged to pay 10% of their earnings to an account which would be used in
case they are not successful.
Data should be escrowed.
Q70: How should ICANN
evaluate the sufficiency of proposed intellectual property protections?
Through
direct control in the "r"-area (registered area - see above), as in .edu. No control
and no IP protection (except copyright) in all other gtlds.
Q71: What role should
ICANN have in the start-up procedures for new unrestricted TLDs?
None.
Q72: In
what ways should the application requirements for sponsored/chartered/restricted
TLDs differ from those for open TLDs?
The proposal of the restricted registry should
contain a clear definition of its policy.
Q73: Should ICANN require a statement
of policy or should a statement of how policies will be made be sufficient?
Every
registry should have to offer an unrestricted AND a resticted gtld at the same time,
using the same name + "r" for "restricted".
The restricted domain should imply
trademark laws, but may extend to further restrictions whatsoever, too.
Q74: What
level of openness, transparency, and representativeness in policymaking should ICANN
require?
All, except financial informations should be open to the public.
Thank
you for reading my comments!
Regards,
Friedrich Kisters