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Comments on Module 5 DAG version 3

  • To: 3gtld-transition@xxxxxxxxx
  • Subject: Comments on Module 5 DAG version 3
  • From: "S. Subbiah" <subbiah@xxxxxxxxx>
  • Date: Sun, 22 Nov 2009 23:07:19 -0800

Module 5


The exact final Registry Agreement (subject to no further change ) should be presented by ICANN no later than the opening of the application period. No application fee of any kind should be charged by ICANN until a final agreement is made available. A process that is 5 to 7 years in the making – new gTLD program – should be capable of producing better than an open-ended contract before asking for hundreds of thousands of dollars to be spent applying. Only monopoly entities like governments – or in this case ICANN – act by such fiat.


In some jurisdictions and countries, with relevance, it may be illegal to sign up for DNSSEC; the absolute requirement for DNSSEC which presumably will be under a US-operated trust anchor subject to the US Patriot Act (whereby a single government has special rights to the private data) will present a challenge if ICANN’s intent is geographical diversity, particularly in its IDN applicants. Even for ASCII gTLD applicants, like “.Moscow” with presumably mayoral support, this will be a challenge.

Again if ICANN insists by setting high standards on escrow by US companies, again subject to the US Patriot Law, it will be a challenge. Besides the US and maybe one or two Western European countries, local escrow operators – say in Mongolia – may amount to not much more than some local prominent law firm keeping the submitted archives. ICANN needs to be much more explicit about Escrow company requirements. An applicant can spend a $1M, win and then in 90 or more days be unable to find an escrow agent with ICANN expectations and still satisfy local national legal requirements say on a “.Moscow” and then lose it all.

Further it is completely bizarre that ICANN can ask for millions to be spent and hundreds of thousand to be spent in a non-refundable fashion and still be unable to upfront promise that a winning TLD will actually go into the root and that it still needs ICANN’s own Board to approve (the own Board of a regular standard US corporation). Given the “.xxx” fiasco there is every reason to worry that ICANN’s own Board will not approve. On top of this there is no guarantee that the US Dept of Commerce (based on its statements when the JPA was replaced by the AoC on Sep 30 2009) will actually agree to put it into the root after the Board approves. Every statement by Justice and Commerce states they probably will not as things stand with ICANN;s refusal to conduct various multi-year studies. There should be a complete guarantee at the time of application start-time that a winning gTLD will have Commerce’s blessing and will go into the root.


IvP6 is not prime-time ready to be tested or otherwise at most of the developing world’s ISPs and data centers. Even in the US adoption has been slow. Given the current economic climate most ISPs and data centers in much of the world are unlikely to invest in the necessary hardware soon. Asking for the software ability to handle IvP6 is one thing, but requiring actual network tests to demonstrate actual live IvP6 implementations and servers is quiet another. Again something geared to help applicants from affluent countries and not from the IDN-needy countries.


Specification 6 of the Registry Agreement suggests that ICANN in essence makes a base of US$25 000 per registry and we expect 500 new registries – some US$12.5M a year. Presumably a base of a few thousand dollars a year for each accredited registrar of the 800+ we now have, resulting in a further few million US$. We already have about 100M mostly ASCII gTLD domains and some additional volunteered from the 100M ccTLD domains pool garnering 0.50 cents each (from registry and registrar) – upwards of US$50M, for a grand total of some US$70m a year minimally going forward. In addition we can expect maybe another maybe 200M domains with the volunteered IDN fast-track ccTLD contributions and the new gTLDs launched, each netting 50 cents in total. ICANN revenue would then be approaching US$200M from the current $50M.

A normal business with this revenue employing even US-based typical salaries will have to employ 1500 employees or 15000 employees in a less developed/least developed nation where much of the names will be sold. ICANN’s main job appears to be monitoring the wired monies from a few hundred contracts and arrange 3 ICANN meetings a year.

Attachment: Module 5.doc
Description: MS-Word document

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