MarkMonitor - Detailed Comments on Module 1

["Elisa Cooper" <Elisa.Cooper@xxxxxxxxxxxxxxx>]

MarkMonitor is pleased to submit the following detailed comments
regarding Module 1 of the Draft Applicant Guidebook.

Section 1.1.2.4 - 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 1.1.2.9 - 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.