We have serious concerns with this application as follows and have presented some
brief examples which reflect a portion of our concerns:
1. Why would ICANN
vest in some small banking association in Monaco the ability to establish and set
policies for a space which represents
world-wide banking interests ? This seems
to be a blatant attempt at
"SELF PROMOTION" by the Monégasque... (quote
from application "The present application for a registry would create substantial
added value to the many efforts conducted by the Government and the Association to
foster the growing recognition of Monaco as a strong European Financial Center "A
TLD like this should be administered and fostered by a much larger International
financial association. There are significant numbers of these institutions available.
Significant control of the growth of the policy making panel is also proposed in
this application which we find to be very bias & limiting.
2.Registrars fees:
This represents an excessive amount and appears to be discrimitory in favor of larger
registrars as compared to the majority of other applications tendered.
3.The market:
These assumption of 1,000,000 potential registrants is totally without basis here.
4.Marketing
& Promotion: A very,very, shallow summary here with many allusions not backed
up by appropriate supporting materials. It would appear to us that the registry is
making no real tangible attempt to support the growth and awareness of this "string"
and is putting the entire burden on the Registrars.Here is a quote from the application
"The registrars will be used as the main marketing channel; the registry will provide
them with SOME basic marketing materials to help them deal with the new type of customers"
("SOME?" BASIC MARKETING MATERIALS ???)
5.Another attempt to leverage "TLD's" into
big profits: We see brief references to "stock options" and "Eurafnet and CSL
plan to introduce a stock option plan for the members of the Netbay staff. It must
be
pointed out that Eurafnet intends being listed by the end of 2000 in Europe.
Netbay shares held by the staff members could then be exchanged for listed Eurafnet
shares." NEED WE SAY MORE ?
6.2nd level TLD reservations by registry. This
proposal leaves open the opportunity to pervert the intent of the "charter concept"
by allowing broader 3rd level registrations in broad second level names reserved
by the registry for "it's own exploitation" such as "loan.fin" or "info.fin" We find
this to be self conflicting..