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Comments on Module 2 DAG version 2

  • To: 3gtld-evaluation@xxxxxxxxx
  • Subject: Comments on Module 2 DAG version 2
  • From: "S. Subbiah" <subbiah@xxxxxxxxx>
  • Date: Sun, 22 Nov 2009 23:02:52 -0800

Module 2 point 5

The choice of at least 69% of countries agreeing (and at most one country objecting) to a gTLD for a continent or a UN region appears to be completely arbitrary. Is there a precedent rationale for this ? end

If an application survives the geographical review and deemed by its rules not violating any of the geographical conditions as stated, can a government object to this later on community grounds (Section 3) ? If governments are already being given clear rights now to protect their “turf”, can they have further rights to be like any other community to object ? If so, seems unfair. Should be prohibited for clarity. Similarly if a gTLD that has some geographical aspect to it – whether it survives the geo review by having government support/non-objection or whether it clears that review by simply not breaking the stated Geo conditions/rules - can an indirect existing competitor, for example the current ASCII ccTLD or IDN fast-track ccTLD operator in a related region, with potential direct material gains (by preventing re-directed revenue) object on community grounds. Seems that this should not be allowed, if the purpose of this new gTLD program is more competition. For example a capital city gTLD sponsored by government will takeaway from the national existing ccTLD operator. Should the existing ccTLD operator be allowed to object ? There normally would be no case of confusing similarity.

A gTLD applicant flagged on a Geo requirement for the need for a support/non-objection letter from government is to be given a limited timeframe to respond in. It would seem that such a limited time frame should be DEFINED now to eliminate possible risk for the applicant. What if ICANN decides to give “20 seconds” to get a support letter in for a gTLD that the applicant always believed and believes is not a geo-TLD. Normally not a problem but with a 1-sided application form where all rights to complain are handed over, no guarantee of outcome or return of funds. Open-ended time frames for go/no-go outcomes does not reflect maturity of the application process – despite it running into a few hundred pages (albeit now cut up into small pieces and attachments to avoid the oft-quoted frustration at its “length”).


What is the purpose of an extended evaluation process (after paying $185K and spending a million waiting for ICANN) if some new material cannot be submitted to improve the application. As it is for an applicant for an IDN in particular and from a technical, financial culture that is different from the US/ICANN one the concept of handling everything online and all communication by email is already an unfair impediment viz a viz a Western large corporation (with no background in that IDN culture) applying for the same desirable IDN TLD. To then not allow a one-time possibility of upgrading a rejected evaluation to allow for misunderstanding of instructions – wrong thing submitted for instance because the culture has no equivalent – is a fundamentally failed approach in trying to make ICANN more equitable globally. With no ability to voice confusion coming from other cultures ICANN will simply be another English-centric corporation serving the interests of other English-centric primarily Western corporations. (I suspect most ICANN staff and Board cannot stop a cab and get to the right place on time in a country/language they are not from themselves. How does ICANN expect a foreign applicant, particularly for IDN, to fill out these voluminous application material absolutely correctly first time around and have no contact accept by online means ? ).


It MUST be made a requirement that for an IDN application, there must be at LEAST one (and preferably 2) panelists on each of the panels who speaks that language and is from that community – preferably from the country that has the largest population of speakers. Else it will be simply another case of yet another US entity telling the rest of the world what is good for them. And it is not a cost issue – in most IDN cases it would cost far far less to hire a panelist from the poorer IDN country than what is budgeted with a US/European in mind already. It is not the cost, it is the will to do so.

Attachment: Module 2 .doc
Description: MS-Word document

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