MarkMonitor - Detailed Comments on Module 3
MarkMonitor is pleased to submit the following detailed comments regarding Module 3 of the Draft Applicant Guidebook. Section 3.1.5 - Independent Objector According to the latest revisions in DAG3, the Independent Objector will be forced to cover filing and administrative fees, which will only be refunded in cases where the Independent Objector prevails. However, with this approach, the Independent Objector is likely to only file objections when a favorable ruling is certain, and may shy away from more questionable, yet still important cases. We would recommend that all filing and administrative fees arising from actions taken by the Independent Objector be covered by the new gTLD application fee proceeds. We also believe that the Independent Objector should be required to conform to the new gTLD Application Program Code of Conduct to prevent any real and apparent conflicts of interest.