Comments Regarding Expressions of Interest Process

[Hugh Haggerty <hugh.haggerty@xxxxxxxxx>]

Dear ICANN,

I would like to state my comments for the current Expressions of Interest 
("EOI") process, and appreciate the opportunity to make my views heard.

OVERALL SUPPORT OR NON-SUPPORT FOR EXPRESSIONS OF INTEREST
I support Expressions of Interest    This proposal makes the TLD process both 
more open in that it will provide more information about a TLD's use and who 
controls it. It also restricts gaming the system by requiring the high fee. 
Also, refunds should be available but not necessarily be given on demand. 

SUBMISSION FEE
There is discussion about the $55,000 (USD) submission fee.   I support a high 
fee to discourage gaming.     A low fee would encourage more speculators who 
just sit on TLDs until the right price came along.

MANDATORY NATURE OF EXPRESSIONS OF INTEREST
There is also a question about whether Expressions of Interest should be 
mandatory for those applying for a new TLD.       I don't think TLDs should be 
under proprietary ownership of single private interests. If more than one 
entitity is interested in a TLD they should be able to work out sharing 
arrangements.

REFUNDS
The current EOI model will provide refunds of the submission fee only in 
extraordinary circumstances, or unless ICANN is unable to accept new TLD 
applications by a particular date.  Refunds should be allowed only in limited 
circumstances.     Limited but not too limited. I'm sure something fair can be 
worked out.

COMMUNICATION PERIOD
ICANN's draft EOI model contemplates a four-month communication period prior to 
accepting EOI submissions. Four months is about right for the communications 
plan.     

PUBLICATION OF DATA
Finally, there is a question about whether data collected from EOIs should be 
made public. ICANN should publish all strings and applicants.     

OTHER COMMENTS
 ICANN's job is sort of like the FCC's in the U.S. for TV and radio. Over the 
years, much of what the FCC does has become shrouded in secrecy. The EOI 
process should help ICANN be both more open and fair in its stewardship of 
TLDs.  

Signed,
Hugh Haggerty 

hugh.haggerty@xxxxxxxxx

[This comment comes via the ICANN comment form found at 
http://www.mindsandmachines.com/2010/01/let-icann-know-your-position-on-expressions-of-interest.
  This form provides brief descriptions of the issues and allows easy comment 
on the Expressions of Interest process.]