<html>
<head>
<style><!--
.hmmessage P
{
margin:0px;
padding:0px
}
body.hmmessage
{
font-size: 10pt;
font-family:Verdana
}
--></style>
</head>
<body class='hmmessage'>
<br>I support the idea that while the BC members discuss their views on this topic<div>on the list, that we do not try to develop a unified BC position. I can't see how</div><div>it is possible to develop a position and take a 14 day vote, and I expect that there</div><div>are many different perspectives which would need to be shared, discussed, and </div><div>then a drafting of a proposed position, with then a 14 day vote period.</div><div><br></div><div>Also, this is now a Board consultation, and it seems useful to have the unique</div><div>voices of different business users, and associations, sharing their perspectives</div><div>in the public comment process. </div><div><br></div><div>Marilyn Cade</div><div><br></div><div><br><br><br><br>> From: michael@palage.com<br>> To: philip.sheppard@aim.be; bc-gnso@icann.org<br>> Subject: RE: [bc-gnso] TLD pre-registration<br>> Date: Tue, 19 Jan 2010 08:38:11 -0500<br>> <br>> <br>> Philip,<br>> <br>> I personally find myself more aligned with your viewpoints than I do with<br>> those expressed by Ron and Liz, however, I do not believe the BC charter<br>> permits a suitable timeframe to submit a constituency statement.<br>> <br>> I have been watching the EOI ballot box stuff exercise and believe it would<br>> be most prudent/effective for individual members to submit their comments to<br>> the forum.<br>> <br>> I have just completed an article in connection with the EOI that I will be<br>> publicly posting to the ICANN forum later today, and will forward it to the<br>> BC list as well.<br>> <br>> Best regards,<br>> <br>> Michael<br>> <br>> <br>> -----Original Message-----<br>> From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of<br>> Philip Sheppard<br>> Sent: Monday, January 18, 2010 4:56 AM<br>> To: bc-gnso@icann.org<br>> Subject: [bc-gnso] TLD pre-registration<br>> <br>> <br>> This is out for consultation.<br>> The public comment period opens on 18 December 2009 and closes on 27 January<br>> 2010. Details at:<br>> http://www.icann.org/en/public-comment/#draft-eoi<br>> <http://www.icann.org/en/public-comment/#draft-eoi> <br>> <br>> <br>> My draft initial comments are as follows.<br>> Comments ?<br>> If there is consensus / support I'd be happy to write something up as a BC<br>> position.<br>> Philip<br>> <br>> --------------------<br>> We oppose the concept of pre-registration and expressions of interest (EOI)<br>> for<br>> the following reasons.<br>> <br>> 1. Distraction<br>> The EOI process should not distract ICANN from the fundamental task of<br>> addressing unresolved issues relating to new TLDs such as trade mark<br>> protection<br>> and malicious conduct. <br>> <br>> 2. A true pre-registration<br>> The proposed mandatory EOI process with a $55,000 fee is described as a<br>> pre-registration suggesting that it is not reversible regardless of the<br>> unresolved overarching issues such as trade mark protection and malicious<br>> conduct. <br>> <br>> 3. Inconsistency<br>> The principle of pre-registration is inconsistent with all previous ICANN<br>> practice.<br>> <br>> 4. Ignores market dynamics <br>> Brand owners may feel compelled to enter into an EOI purely for defensive<br>> reasons, so that they do not suffer when a speculator is given rights in<br>> their<br>> brand. There seems to be no facility to allow competition for the same<br>> domain<br>> names after pre-registration. Moreover, pre-registration may tip-off<br>> competitors<br>> to new business models prematurely.<br>> <br>> 5. A lower than market fee may encourage speculation<br>> Speculators may pay $55,000 to secure rights to certain domains instead of<br>> $185,000 in the hope of selling on. This is surely not the intent of ICANN's<br>> Board.<br>> <br>> 6. Applicants are forced to invest blind<br>> Because there are unresolved issues, the pre-registration model forces<br>> applications in ignorance of potential future costs. This is poor business<br>> practice.<br>> <br>> <br>> Philip Sheppard<br>> <br>> <br></div> </body>
</html>