Use of a Drawing for Prioritizing New gTLD Applications (Comment)
Dear ICANN, We believe that the drawing mechanism is appropriate, yet some modifications should be made as follows. A. Issue of one applicant with multiple applications There is a clear probability benefit for those who applied for more than one application. To foster competition, ICANN should avoid this; ICANN should ask applicants with several applications to select a priority and then establish several rounds of drawing in this way: 1. IDN draw. 2. First draw: single application applicants and the top priority application for multiple application applicants. 3. Second draw: the second priority application for multiple application applicants. And so forth. B. Issue of competitor Many applicants’ concern is not their absolute time to market but their relative time to market. This is how separated their TLD delegation is from that of their competitors. Under the current drawing system, if their competitor was to be number one and the applicant last, the difference between the delegations could end up being more than one year, which is not acceptable. A solution could be to ask each applicant to name up to three or five strings that they themselves consider being a competitor. After all links have been established, a group of competitors are created and these subsets of competitors would be drawn together. The order between subsets could be established randomly since absolute time is not so important as long as an applicant is in the same subset as the competitors. NOTE: To avoid conflicts with applicants with multiple applications, the selection of three/five competitors should be done among the ones in the same draw (from point a). Otherwise, if point (a) is not implemented, multiple application applicants should only be allowed to select up to three/five competing applications overall against a TLD they applied for. Regards New gTLD Team Brights Consulting Inc.