Comments Regarding Expressions of Interest Process

[Thomas Gilles <tgilles@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 I urge ICANN to allow the process of 
introducing new gTLD's to move forward by initiating the Expressions of 
Interest.

The Expressions of Interest proposal will help the TLD process move forward 
while allowing time to address concerns.  It will also provide valuable 
information for ICANN to determine the scale of the new gTLD round.


 

SUBMISSION FEE
There is discussion about the $55,000 (USD) submission fee.   I support a high 
fee to discourage gaming.  I believe the $55,000 fee is sufficient to help 
minimize 'gaming' of new TLD applications. The amount will help ensure that 
only serious applicants for a new TLD registry will apply. 

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.  New TLD applicants should be 
required to submit an EOI.  Mandatory expression of interest will provide 
information to help ICANN grasp the scale of interest in new TLD registries. By 
making the EOI submission and fee a prerequisite for new TLD application, ICANN 
can more accurately address technical and intellectual property concerns. This 
will make the process and implementation of new TLD's more secure, stable and 
manageable.

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.  VERY limited circumstance.
A highly restrictive refund policy will help ensure only serious applicants are 
involved.


COMMUNICATION PERIOD
ICANN's draft EOI model contemplates a four-month communication period prior to 
accepting EOI submissions. Four months is too long for the communications plan. 
 I believe a public outreach campaign could raise complications in the 
implementation of new TLD's. It's important to try keep the number of new TLD's 
within a manageable range. Widely broadcasting the TLD round will increase the 
number of applicants.

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.  The EOI results 
need to be open and transparent. When  a mandatory, nonrefundable fee is 
instituted, only  serious applicants will be involved. 



OTHER COMMENTS
ICANN needs to move forward with its directive to expand the internet namespace.
Opponents of the process are acting only in self interest, not for the common 
benefit.
Demand in the domain name market has created unreasonably high prices for 
viable domain names.
The result is an artificial barrier to entry for prospective individuals and 
businesses to expand into the the space.  

Signed,
Thomas Gilles 

tgilles@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.]