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DOTZON Comments on Applicant Guidebook - April 2011 Discussion Draft

  • To: <6gtld-guide@xxxxxxxxx>
  • Subject: DOTZON Comments on Applicant Guidebook - April 2011 Discussion Draft
  • From: "Katrin Ohlmer" <katrin@xxxxxxxxxx>
  • Date: Sun, 15 May 2011 18:19:51 +0200



DOTZON consults companies and organizations how to apply for their own
generic top-level domain (gTLD) e.g., .brand, or .company. Our clients
include German industry leaders (DAX 30 stock market index) and Internet
companies. In this capacity we would like to make comments to the sixth
draft of the Applicant Guidebook.


First of all - we look forward to the Release of the final Applicant
Guidebook on June, 20 in Singapore.


1. Remove restrictions on 2-character Labels

Status: The introduction of a mandatory reservation of "Two-character
labels" in new gTLDs is not understandable and has not been a proper
community discussion. Just months after the latest delegation of two letter
.de-Domain names no confusion has been reported so far: fr.de is run by a
large Frankfurt-based newspaper (Frankfurter Rundschau), no confusion with
the French ccTLD .fr  has been reported, it.de is run by netzwelt.de, one of
the biggest German news portals for IT & consumer electronics and no
confusion with the Italian ccTLD .it has been reported.

Recommendation: Remove 2-character-label reservation.


2. Provide details on batching in case of more than 500 applications

Status: Until today details about batching are not available, apart from
basic information that a separate process has still to be established.

Recommendation: Clarification on the batching process has to be included in
final AGB.


3. Provide details on .brand (SRSU)

Status: In particular applicants for a .brand TLD need more details and
planning reliability on costs, requirements, and processes. So far only few
details are included in the AGB like in the Registry Operator Code of

Recommendation: Clarification on the special requirements for .brand TLDs
have to be included in final AGB.


4. Provide details on Trademark Clearinghouse

Status: As of today it is unclear how the Trademark Clearinghouse shall be
integrated in the registration process as well as details on the costs
associated for Trademark holders and registries using the clearinghouse.

Recommendation: Specifications on how to connect to the Trademark
Clearinghouse from a new gTLD registry have to be included in final AGB as
well as further details on processes and costs.


One final remark with regards to the latest numerous attempts to delay the
new gTLD process further claiming that the introduction should not be 'in a
rush' or took place without the involvement of all stakeholders. There have
been thousands of opportunities over the last six years to comment documents
and policies, participate in working groups, and attend ICANN meetings in
person or remote. Based on ICANNs bottom-up multi-stakeholder model all
parties involved have had the chance to interact and give their opinions.
Nobody can say that her/his voice has not been heard. The nature of
bottom-up models is a compromise which naturally can't meet everybody's
wishes. Now trying to undermine this bottom-up model is not only selfish but
also does not acknowledge the whole ICANN model.


We would like to thank ICANN for the opportunity to comment.


Katrin Ohlmer, CEO, DOTZON GmbH
Berlin, Germany

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