We oppose the EOI process as premature and a distraction from the important issues

[George Kirikos <gkirikos@xxxxxxxxx>]

We oppose the proposed EOI process as premature, and a distraction from the 
important issues facing the internet. As proposed, it simply represents an 
attempt by "insiders" to game the process to their advantage. Nice try, but it 
should obviously be rejected. Ponying up $55,000 doesn't replace the need for 
real economic studies of the gTLD ecosystem -- consulting with registrants and 
users, not gTLD-speculators and their paid consultants.

There have been no appropriate economic studies performed that address new 
gTLDs, and those need to be completed before deciding whether new gTLDs should 
be added to the root. The Affirmation of Commitments is very clear on this 
point:

http://www.icann.org/en/documents/affirmation-of-commitments-30sep09-en.htm

"To ensure that its decisions are in the public interest, and not just the 
interests of a particular set of stakeholders, ICANN commits to perform and 
publish analyses of the positive and negative effects of its decisions on the 
public, including any financial impact on the public, and the positive or 
negative impact (if any) on the systemic security, stability and resiliency of 
the DNS."

Where is the list of "negative effects" published by ICANN, and an economic 
valuation of the financial size of the positive vs. the negative effects to 
determine whether the benefits exceed the costs of new gTLDs? That report has 
either never been done (presumably because ICANN knows that the outcome will be 
against its ambitions), or has been done but has never been published because 
it would end the careers of various ICANN insiders who've been working against 
the public interest for years with their boondoggle ideas. This is the same 
staff who never analyzed the economic costs of the VeriSign settlement (which 
allowed 7% annual price increases), despite repeatedly being asked for them. 
Now, consumers are being exploited even further by that monopoly (which will 
hopefully one day be dealt with either by the CFIT lawsuit or by the US DOJ 
anti-trust division).

Furthermore, this process is not a one-time event, it must be continuous:

"continually assessing the extent to which ICANN's decisions are embraced, 
supported and accepted by the public and the Internet community;"

ICANN constantly points to a single vote made years ago by the GNSO Council, 
which had double-weighted and was thus captured by the registry and registrar 
constituencies. That hurdle is much higher today, under the AOC. It must 
*continually* assess whether decisions are supported and accepted by the 
*public* and the internet community. While there is support for IDN ccTLDs, 
IPv6, DNSSEC and aliased (DNAME) gTLDs, there is scant support for a wild-west 
process for the introduction of tens of thousands of new gTLDs available to 
anyone who can grease ICANN's pockets with cash. There are tens of millions of 
registrants in existing gTLDs who do not want to be compelled to purchase 
defensive registrations under a protection racket sanctioned by ICANN. They 
demand rollbacks in *existing* registry monopoly fees, and lower ICANN fees too.

We have seen new gTLDs that were hyped like .asia, .travel, .name, .tel and 
.pro go nowhere and attain no traction. ICANN has not deconstructed or analyzed 
why this happened, yet pretends that "this time it will be different."

Some have defined "insanity" as "doing the same thing over and over and 
expecting a different result." This clearly is the case for ICANN and new 
gTLDs. The only people laughing are the highly overpaid ICANN insiders, who 
parade around the world as if they were the IOC. They're laughing all the way 
to the bank, while taxing the internet by hundreds of millions of dollars per 
year through their poor decisions.

Perhaps it also fits those of us who must also continually point out ICANN's 
flaws, only to be ignored by a self-serving staff and organization that 
operates for its own private benefit, as is widely known through its 
compensation practices and organizational waste:

http://www.circleid.com/posts/20090105_icann_for_profit_companies_comparables/

Now that the AOC is in place, it is our hope that the DOC will finally reign in 
ICANN's foolishness, end the insanity, and instead work towards policies that 
the public supports, in particular stability and security. This can be done 
through a much smaller and focused organization, not the circus that we have 
today. While most organizations in these tough economic times are reigning in 
waste, ICANN believes it is party-time all the time. Several million dollars so 
that the new CEO can have an office in Palo Alto? No problem. Millions of 
dollars to staff that have no basis in reality when compared to other 
non-profit organizations? No problem. When for-profit organizations cut 
compensation due to the weak economy, does ICANN do the same? Certainly not, 
they keep increasing them, hoping that no one reads the annual Form 990.

http://forum.icann.org/lists/bc-gnso/msg00134.html

If new gTLDs are to go forward, they should be allocated in a method that 
maximizes the public interest, namely via regular tenders as per government 
procurement contracts, to the registry operator that will operate the service 
at the lowest cost per domain name per year, for fixed-length (5 year) 
contracting terms. Clearly ICANN is not doing this, because they have no 
interest in maximizing any benefits to the public. Their only goal is to 
maximize the amount of cash flowing towards ICANN.

Sincerely,

George Kirikos
President
Leap of Faith Financial Services Inc.
http://www.leap.com/