dotHAMBURG Comments on the draft Expression of Interest (EOI) / Pre-Registrations model

[""Oliver J. Süme"" <sueme@xxxxxxxxxxxxxxxx>]

Dear ICANN-Team,

please find attached the comments of dotHAMBURG on the draft model of  
an EOI /
Pre-Registration model.


• Responses to the request for EOI are mandatory for eligibility to  
submit a gTLD application in the first round. Subsequent application  
rounds are open to any eligible applicant.
Comment: Since the final requirements have not been defined yet the  
EOI must be voluntary. It should also not be treated as a pre- 
registration process.
• A deposit of US$55,000 is required for the EOI, as a credit against  
the evaluation fee.
Comment: The EOI deposit should be reasonable.

• The deposit is refundable if the New gTLD Program does not launch  
within a specific time period.
Comment: If the application or registration process does not start  
within 6 month after filing the EOI, the amount shall be refunded.
• Participants are notified that there will be subsequent changes to  
the Applicant Guidebook, and that there are limited terms for refund  
based on such changes. It is the intention to conclude many  
outstanding issues (for example, discussions of issues concerning  
vertical integration and the IDN‐3 character issues) prior to  
initiation of the EOI process, through the publication of draft  
version 4 of the guidebook.
Comment: To start a process and call it pre-registration without the  
final requirements approved by the ICANN board is against ICANNs  
practice and not acceptable. All that is needed now is basic  
information as to the number of potential applicants. ICANN should  
provide other incentives for the parties to participate in the EOI  
process.
• A fully executed communications campaign, intended to ensure global  
awareness of the program, will precede the opening of the EOI process.
Comment: The EOI communications campaign should substitute any further  
communication campaigns.
• A specific set of information concerning the participating entity  
and the intended string is collected from EOI participants.
Comment: The information gathered should be limited to the minimum  
needed to achieve the initial goal of the EOI – numbers and kinds of  
applications.
• The participant and string information will be made public.

Comment: We think this should be voluntary since there are a number of  
valid reasons which could stand against a publication of this  
information. In cases where the applicant does not wish his name and  
the string to be published, the data should be anonymized instead.
Having stated all of the above, we urge ICANN to complete the gTLD  
process as quickly as possible!
The EOI procedure must not lead to any further delays in the new gTLD  
process!
Best regrds,

Oliver Sueme
Founder / CEO
Initiative dotHAMBURG e.V.
Gertigstr. 28
22303 Hamburg
Germany