Comment from the Department of Information Technology of Moscow

[Арабей Александр Сергеевич <ArabeyAS@xxxxxx>]

Dear Sir/Madam,
The Department of Information Technology of Moscow, the relevant public 
authority supported the implementation of .MOSCOW top-level domain and its 
Cyrillic version .МОСКВА within the New gTLD Program, welcomes the Draw 
proposal ICANN devised to determine the order of introduction of the new 
top-level domains.
We consider the Draw as a fair and efficient way to complete the first round of 
the New gTLD Program in a timely manner addressing the needs of the global 
Internet community.
Being a party that is actively involved in the implementation of .MOSCOW and 
.МОСКВА top-level domains, we would like to ask ICANN to evaluate the 
possibility of giving a priority to the geographical TLDs in the Draw as it is 
done for IDNs.
A few arguments for taking such an approach:

1.      GeoTLDs are supported by the relevant public authorities that 
officially represent a number of local communities (residents of the respective 
regions and cities).

2.      Geographical TLDs will make visible contribution to the development of 
the Internet in the public interest as they are introduced for the needs of 
palpable communities.

3.      There is a small number of applications for geographical domains 
comparing the total number of applications submitted within the first round of 
the New gTLD Program. That means prioritization of geoTLDs additionally to IDNs 
will not cause any appreciable delay in the implementation of the rest 
top-level domains.

4.      Some geographical strings planned to be implemented both in ASCII and 
as IDNs. That is the case for .MOSCOW and .МОСКВА. For the community of 
Muscovites the TLDs are targeted at there would be much more clarity and 
transparency if both strings are launched at the same times - this may not 
happen if the Draw proposal gives a priority to IDNs only.
Appreciating the fact the Draw is being developed in the strong cooperation 
with the Internet community, we hope our thoughts will be carefully considered 
by ICANN and could become useful for the procedure improvement before it goes 
live.
Best Regards,
Alexander Arabey,
Council of the Department of Information Technology of Moscow