[bc-gnso] Draft v1 of BC comments on latest gTLD Guidebook

Mike Rodenbaugh icann at rodenbaugh.com
Fri Apr 29 06:21:13 UTC 2011

I agree with Jon and Jarkko's points.  Also I think we might want to focus
on the "Single-Registrant" carveout in the Code of Conduct, to clarify that
the latest Guidebook has made some progress in recognizing this category of
registry operators, but still has left the definition murky.  I think the BC
provided a clear definition, and I have not seen how it was considered by
Staff.  I am happy to help with that portion of the comments, and others if


Mike Rodenbaugh


tel/fax:  +1 (415) 738-8087

 <http://rodenbaugh.com/> http://rodenbaugh.com


From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of
Jon Nevett
Sent: Thursday, April 28, 2011 5:56 PM
To: Steve DelBianco
Cc: 'bc-GNSO at icann.org GNSO list'
Subject: Re: [bc-gnso] Draft v1 of BC comments on latest gTLD Guidebook



Thanks for pulling this together.  


I agree with Jarkko on his point about not limiting the round to an
artificial number.  The round will be limited based on a number of factors,
including price, duration, technology, etc.  There will be a natural
batching and timing deviation for the reasons Jarkko mentions as well.    


Also, could you confirm that the GAC (in either its scorecard or subsequent
responses) does, indeed, support each of the bullet points quoted below as
we imply that it does?  I think that we should be sure that we are entirely
factually accurate on these.     


Finally, I would support a shorter set of comments with just the highlights
or summary points instead of another 19 page comment set.






"However, many other BC comments have been disregarded without explanation,
despite agreement from multiple stakeholders, including the Governmental
Advisory Committee (GAC). Notable are several previous BC recommendations to
raise the integrity and availability of new gTLDs:

.       *The first batch should be limited to significantly fewer than 500
applications, in order to test the operational readiness of newly designed
application processing and objection / contention systems.

.       *Applicants should be granted fee reductions for additional versions
of the applied-for string in IDN scripts and other languages.

.       *String Similarity contention sets should not include similar
strings requested by a applicant seeking linguistic variations of the
applicant's other applied-for string.

.       *Applicants should be required to pay an objection Response Filing
Fee in order to defend the rationale already included in their original

.       *Community priority evaluation should be given to applicants scoring
at least 13 points, not 14. 

.       *RPMs are still substantially weaker than those recommended by the
IRT.  Consumers and businesses will inevitably be harmed by cybersquatting
and other fraud likely to occur in hundreds of new gTLDs, especially at the
second level." 




On Apr 27, 2011, at 2:57 PM, Steve DelBianco wrote:

Per discussion on our 21-Apr member call, here is a draft framework for BC
comments on the 15-Apr-2011 Guidebook.


This comment period and docs are described at

These comments are due 15-May, giving us 18 days for edits, review, and


For this initial draft, I updated our Dec-2010 Guidebook comments in several

- Acknowledged areas where ICANN made changes consistent with BC

- Moved all our RPM concerns to Module 5

- Asked several questions for BC members (in red) 

- Added a proposed definition for "Single-Registrant TLD".   We may hold a
separate call on this.


All BC members are invited to suggest edits.     Please use track changes
and circulate to BC list.   

I will assemble another draft version with all changes received as of May 1.


Below are the primary contributors from our Dec-2011 comments, organized by


Module 1: Introduction to New gTLD Application Process and Fees.  (Berry
Cobb, Ron Andruff )


Module 2: Evaluation Procedures.    (Philip Sheppard, Jon Nevett,  Adam
Palmer,  Zahid Jamil,  Sarah Deutsch )


Module 3: Dispute Resolution. ( John Berard, Ron Andruff )


Module 4: String Contention.   ( Ron Andruff )


Module 5: Transition to Delegation; Registry Agreement, Code of Conduct,

( Philip Sheppard, Fred Fellman,  Berry Cobb, Jon Nevett, Sarah Deutsch )



Other notes:

In our SFO comments, the BC said the new gTLD communications plan should
help the world's businesses and users understand changes coming in the DNS.
But I didn't see anything in the latest Guidebook about the Communications
Plan. So that comment was not reflected in the attached draft. 




Steve DelBianco

vice chair for policy coordination


<BC on Apr-2011 App Guidebook.docx>


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