MarkMonitor - Detailed Comments on Module 1
MarkMonitor is pleased to submit the following detailed comments regarding Module 1 of the Draft Applicant Guidebook. Section 184.108.40.206 - Objection Filing The current version of DAG3 provides for a two-week window for the filing of objections from the posting of the Initial Evaluation Results. We recognize that objections can be filed as soon as applications are posted upon completion of the Administrative Check. However, it is likely that the majority of people will refrain from filing objections until an application has actually passed the Initial Evaluation. This may be especially true in cases where multiple applications for the same string have been submitted. The two- week time period is therefore too short. Consequently, we ask that the two-week window for filing objections be extended to 30 days at a minimum. Section 220.127.116.11 - Lifecycle Timelines The addition of lifecycle timelines describing the anticipated length of each phase enables registries, registrars and corporations to gain a better understanding of the entire process. Although the inclusion of launch timelines is noticeably missing, ICANN's commitment to ensuring that solutions to the four overarching issues are identified prior to announcing anticipated launch dates is commendable. Section 1.2.1 - Eligibility We commend ICANN staff for incorporating additional safeguards prohibiting registry ownership of more than 15% by those who have been: convicted of a felony, or a financially-related misdemeanor, subject to ICANN disqualification, or involved in cyber squatting or other domain name related fraud. Section 1.6 - Questions about this Guidebook The availability of the Question and Answer Forum during the Submission Period is an extremely positive addition to the process and should help to reduce the need for Extended Evaluations.