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"Comments Regarding Strategy for Introduction of New gTLDs"

  • To: gtld-strategy-draft@xxxxxxxxx
  • Subject: "Comments Regarding Strategy for Introduction of New gTLDs"
  • From: "anthony p. fusco jr." <afuscojr@xxxxxxx>
  • Date: Thu, 14 Oct 2004 11:24:32 -0400

<html><div style='background-color:'><DIV class=RTE><B><U><FONT size=3>
<P align=center>Comments for Submission via E-Mail to ICANN</P>
<P align=center></P></U></FONT><FONT face="Times New Roman">
<P>To: gtld-strategy-draft@xxxxxxxxx</P>
<P>From: MWC Group, Llc., Jeffrey Galpern (Chairman/CEO) and Anthony P. Fusco 
Jr. (President)</P>
<P>Subject: Comments Regarding Strategy for Introduction of New gTLDs</P>
<P>Date: October&nbsp;14, &nbsp;2004</P>
<P>MWC Group, Llc. submits these comments in response to the ICANN Staff Report 
entitled "Strategy: Introduction of New Generic Top-Level Domains" (Staff 
Report), which was released on September 30, 2004.</P>
<P>By way of introduction, MWC Group, Llc. has recently been organized pursuant 
to the laws of the state of Texas. The company?s principal officers are Jeffrey 
Galpern, Chairman and Chief Executive Officer, and Anthony P. Fusco, Jr., 
President. Each of us has expertise and more than forty-five years of 
experience encompassing various business models. Our sole purpose in forming 
MWC Group, Llc. is to seek to obtain and administer a generic top level domain 
(gTLD) as part of the Domain Name System, that will operate on a commercial 
basis to serve companies extensively engaged in international business and to 
facilitate international commerce. </P>
<P>We would like to commend ICANN for the initiative it has taken in seeking to 
develop and implement new policies and procedures for the creation of gTLDs. We 
look forward to monitoring the proceedings outlined in the Staff Report, and we 
will consider submitting further comments as these proceedings progress. We 
also appreciate the efforts ICANN has undertaken in pursuing a level playing 
field for use of the Internet by the international business community.</P>
<P>The Staff Report outlines a number of issues relating to the creation of new 
gTLDs. One of these issues -- the determination and implementation of 
appropriate allocation methods -- is of particular importance to competitive 
new entrants such as our company, and we would therefore like to address this 
issue briefly in these comments.</P>
<P>The Staff Report indicates that the Organization for Economic Co-operation 
and Development (OECD) recently recommended that a price mechanism be used as a 
method for the allocation of new gTLDs, and the Staff Report listed a number of 
allocation methods that could incorporate a price mechanism. The Staff Report 
described one of these mechanisms as follows: "On-going programs where baseline 
criteria for the establishment of new gTLDs are published and maintained. 
Applicants can, at any time, apply for a new gTLD. If the applicant meets the 
criteria, they will enter negotiations to execute an agreement that provide[s] 
for the establishment of a new gTLD registry."</P>
<P>Based upon our own initial review and our discussions with peers, our belief 
at this time is that this mechanism, which would permit applications at any 
time, would serve as the best means of promoting the public interest and 
furthering ICANN?s core values. Specifically, ICANN has recognized from the 
time of its founding that one of its core values is to introduce and promote 
competition in the registration of domain names, and that market mechanisms 
that support competition and consumer choice should drive Internet management 
because such mechanisms will lower costs, promote innovation, encourage 
diversity, and enhance user choice. See Summit Strategies International, 
"Evaluation of the New gTLDs: Policy and Legal Issues," July 10, 2004, at 104 
(and documents quoted and cited therein).</P>
<P>In our view, the "ongoing programs" mechanism would be successful in 
promoting these competitive goals because the mechanism would provide a fair 
and ongoing opportunity for qualified entities to seek entry into the top level 
domain registry marketplace. Promotion of new entry can serve as a powerful 
incubator for competition, and we believe that this mechanism is a promising 
vehicle for fostering new entry. In addition, given the current state of the 
gTLD market, we believe that ICANN would be well served by acting vigorously to 
promote competition in the market. OECD has pointed out, for example, that 
"[i]f the gTLD registry market is treated as a standalone market, VeriSign?s 
market share clearly makes it the principal player with 85% of all 
registrations." OECD, Working Party on Telecommunication and Information 
Services Policies, "Generic Top Level Domain Names: Market Development and 
Allocation Issues," July 13, 2004 (OECD gTLD Report), at 15. OECD has also 
 that "a greater range of registries should . . . increase the level of 
competition between registries." Id.</P>
<P>The Staff Report, in describing the "ongoing programs" option, references an 
important proviso, namely, that applicants must meet qualifying criteria before 
negotiations will be commenced to execute an agreement. MWC Group, Llc. 
strongly endorses this proviso. It is imperative that any entity chosen to 
serve as a registry operator must have the necessary credentials, including a 
detailed and effective business plan; technical and operational resources and 
expertise; financial and other resources necessary to perform successfully as a 
gTLD registry operator; and the ability to partner with other entities to 
ensure effective management of the registry. MWC Group, Llc. has assembled a 
team and designed a program that we are confident will meet the criteria 
applied by ICANN to applicants for new gTLDs. We look forward to the 
opportunity to participate in the procedures being developed by ICANN for the 
allocation of new gTLDs and to demonstrate our capabilities and plans for u!
tilization of a new gTLD.</P>
<P>Although we have noted that, based upon our review of the various options 
summarized in the Staff Report, MWC Group, Llc. favors the "ongoing programs" 
option for allocation of new gTLDs, we also look forward to a more extensive 
discussion of all the alternatives mentioned in the Staff Report, as well as an 
examination of practical and technical considerations relevant to the "ongoing 
programs" option. For example, we understand that, as OECD has observed, an 
"ongoing programs" option would be workable if ICANN concluded that no factors 
would impede the introduction of a large number of new gTLDs. See OECD gTLD 
Report at 38 ("[I]f ICANN hypothetically decided there were few or no technical 
barriers to introducing a very large number of new gTLDs, then allocation 
mechanisms, as opposed to any other procedural requirements or safeguards, 
would be unnecessary to the extent that new gTLDs could be given out on demand 
to qualified candidates."). Thus, it will be important for !
ICANN and interested parties to explore technical issues associated with 
introduction of large numbers of new gTLDs, in order to evaluate the viability 
of the "ongoing programs" option. We believe this exploration of technical 
issues will be of critical importance because of our view that the "ongoing 
programs" option, if it proves to be viable, would bring significant 
competitive benefits.</P>
<P>Finally, we would like to encourage ICANN to move swiftly to complete the 
processes outlined in the Staff Report, so that ICANN can then proceed 
expeditiously with the creation and allocation of new gTLDs. Doing so will 
serve to fulfill ICANN?s goal of promoting robust competition and consumer 
choice in the management of the Internet.</P>
<P>MWC Group, Llc.</P>
 Anthony P. Fusco, Jr.</P>
<P>Chairman and 
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