Brief Comments on Draft RFP re sTLDs

[Bob Jacobson <bluefire@xxxxxxxx>]

Dear ICANN:

I was a member of the SRI International team that proposed adoption of the
".geo" TLD in 2000 (http://www.dotgeo.net/dotgeo).  Our proposal was rated
No. 1 not only by independent authorities but also by ICANN's own staff.  We
did not receive the board's approval, but everything about our proposal
merited its support.  Our TLD was not burdened by many of the problems that
caused other applications to be disapproved.  It's a pleasure to see that
the opportunity to apply for and have approved a TLD may be in the works.

In the comments that follow, I do not speak for SRI International, only as a
private individual -- one, however, with considerable experience dealing
with the TLD approval process.

In the short time I've had to look over the Draft RFP, I find nothing
objectionable and much commendable, especially the expedited application
process and abridged application requirements.  However, I believe the
$25,000 application fee is unnecessary, redundant, and possibly discouraging
to former applicants.  The fees paid in 2000 were already more than was
required to carry out ICANN's role; moreover, this time around, at least in
the case of .geo (were SRI to reapply), there's nothing new to discover.
Given the rapid evolution of the Web, the reasons for granting the .geo TLD
are even more compelling.

Why should any applicant have to pay twice for the approval that would have
been granted, had there been one or two additional slots, and can be granted
now with little additional effort, assuming that the facts are unchanged?

Perhaps a fairer way of levying the charge would be to make it
post-approval.  If a TLD is approved, the sponsor must pay the charge.  This
is appropriate given that all of the applicants this time around will have
already paid the fee once before and been evaluated once before.

At the very least, the upfront fee should be nominal, not substantive,
perhaps "earnest money" of $5,000.  The remaining fee can be paid
post-approval.

The Draft RFP is a very reasonable first effort.  I may have additional
comments in response to further drafts.  Thank you for receiving my comments
pertaining to the Draft RFP's fee structure for applications.  Please call
upon me for any clarifications of my position or my points.

   Bob Jacobson


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