The program of new TLDs should be STOPPED due to lack of interest from the internet society

[Søren Ingemann Larsen <SL@xxxxxxxxxxxx>]

Thanks for giving the internet community - the real and legitimate owners of 
the internet - the opportunity to express our views in relation to yet another 
Draft Applicants Guidebook, now number 6.

But the question is for what purpose further comments should be given, when the 
comments and concerns, well founded and well argued for the most part, are not 
taken into account by ICANN. - This is especially true as far as the question 
of the protection of trademark rights are concerned.

And one huge problem here is that nothing obliges ICANN to listen and take into 
account the comments and concerns of the legitimate owners of the internet, 
namely the USERS, including the trademark owners.

And it is interesting that we are given the opportunity to send in comments 
(without any guarantee of being listened to) only in relation to DETAILS of the 
proposed gTLD program, but not in relation to the very legitimacy of the 
program. To my knowledge we have never been given the opportunity to express 
our opinion as to whether or not it is a good idea to introduce such a new gTLD 
program at all.

If the real and legitimate owners of the internet were to decide whether or not 
we think it is a good idea to introduce this new gTLD program, I am 100% sure 
from discussions with colleagues, that it would never have been introduced. But 
unfortunately this decision has been taken by everyone else than the USERS of 
the internet.

And ICANN still has not presented evidence and convincing arguments to support 
the idea of introducing this gTLD program.

It is obvious that the brand owners will have to fight for exactly the same 
domain names with the new proposed program as they are with the present system. 
The only difference is that with the new proposed program much more money is 
involved than with the present system. No other difference.

The only way ICANN can get away with not presenting the documentation mentioned 
above is that the real and legitimate owners are not given reasonable 
representation in the decision boards. And it is apparently too difficult to 
create political will and support to amend this deficiency.

It is not difficult to see who are interested in this new very expensive 
program. These parties are not the ones that have to PAY the money involved in 
it, but the ones that are going to EARN this money.

The ones that are going to pay are the legitimate owners of the internet, 
namely the users (including the private users and companies owning domain 
names), and the ones that are earning money from this proposed program are the 
registrars and ICANN itself.

The result will inevitably be that the internet from being a cheap and useful 
communication tool open for practically everyone, is now turning into a money 
machine. There is absolutely nothing to be gained from this scenario from the 
perspective of the users of the internet, but only from the perspective of the 
entities who are hoping to make money out of it.

With the present well functioning low cost set up for the internet, the freedom 
of speech is secured for the many. The present programme of introduction of new 
TLDs is associated with very high costs and could therefore evolve into a 
limitation of the freedom of speech for the many.

The process of introducing this new proposed - extremely expensive - program of 
new gTLDs should therefore be STOPPED immediately and only considered again 
once ICANN has produced convincing documentation that the internet society - 
the real and legitimated owners of the internet - is interested in this program.

Kind regards


Søren Ingemann Larsen
Trademark and Domain Name counsel
H.Lundbeck A/S
Ottiliavej 9
DK-2500 Copenhagen Valby
Denmark
Dir.: +45 3643 2123
Mob.: +45 3083 2123
Fax: +45 3643 8301
sl@xxxxxxxxxxxx
www.lundbeck.com