[gnso-rpm-wg] FOR REVIEW & DISCUSSION: Draft collated proposal for Sunrise-related data collection

George Kirikos icann at leap.com
Thu Aug 10 11:31:28 UTC 2017


How can *objectively* argue that sunrise program has been a success (I
can see how one can argue the political angle, but we're not here to
argue politics, we're here to look at facts and evidence), when the
data says otherwise? We know that on average a mere 130 registrations
occur per TLD in sunrises, which means that the benefits are small,
and one must compare those with the costs.

Let's try to put 130 per TLD in perspective. I was looking for stats
on the .eu sunrises, and perhaps others have better sources, but
according to a Google search for ".eu sunrise period registrations
total" one of the hits was to the book "Information Technology Law"
(Diane Rowland et al), it stated there were 346,218 applications filed
for 245,908 different domain names. Those numbers don't provide a
citation, but they seem consistent with a Eurid report:


which states (page 9) that the validation agent had validated (while
sunrise validations were still in progress) 140,000 applications.

I couldn't find the .info stats (although I did find that there were
more than 15,000 *challenges* to sunrise registrations, see
so the aggregate total must have been much higher ),  but I did find
the .asia ones, where there were 30,780 sunrise domain applications:


Calzone.org provided their own stats:


.xxx sunrise: 80,000 blocks (2011)
.co sunrise: 11,000 domains (2010)
.asia sunrise: 32,000 domains (2008)
.mobi sunrise: 15,000 domains (2006)
.eu sunrise: 140,000 domains (2006)
.biz IP claims: 80,000 (2001)

If new gTLDs had anywhere close to those sunrise statistics, it would
be clear there were substantial benefits, and there would be no
argument from me. If that was the data, anyone would be laughed at for
trying to seriously suggest the benefits were small, given the large
uptake. I would be on the other side, arguing that the benefits were
obviously high.

But, that *isn't* the data. We know that the numbers are very small.
So, let's face the facts, the sunrises were a complete disaster in
terms of uptake. That speaks directly to the "benefits" part of the

And we know what the costs were, I won't go into them again.

So, again, I ask anyone to objectively attempt to argue that the new
gTLD's sunrise policy was a success, given those disastrous figures
compared to .eu, .xxx, .co, .asia, etc. (perhaps someone else can add
the complete .info stats with citations, so that we have a full

Instead, the only "basis" for perpetuation of the failed policy is
"let's not rock the boat", or "GAC members might get upset"
essentially, rather than calling a spade a spade --- it's been an
obvious failure.

Let's do our job, look at the evidence objectively and fairly, and use
evidence-based policymaking.


George Kirikos

On Thu, Aug 10, 2017 at 6:42 AM, Jon Nevett <jon at donuts.email> wrote:
> I'm sorry George if my email wasn't sufficiently clear, but after debating mandatory sunrises for literally 8 years of my life I think that the time has come to call the debate in this round.  While I would support the original IRT proposal to make either sunrise or claims mandatory, I do not support simply throwing out the sunrise requirement for the future.  If we cut that kind of a hole in the RPM "tapestry" (old timers might appreciate the reference or not), then we will have to fill it somewhere else. That's just the reality.  I have not heard or seen any persuasive evidence or comments to change the 2012 requirements on sunrise, but I have seen from Kurt and others a strong rationale for keeping sunrise mandatory.  The point that I made about registries doing it anyway should go to the concerns raised about the harms of a sunrise process  -- it generally will happen anyway, but registries should have the flexibility to minimize such harms.  I would be happy if the debate moved on the Claims where we might have more alignment.
> Best,
> jon
>> On Aug 10, 2017, at 12:35 AM, George Kirikos <icann at leap.com> wrote:
>> Hi folks,
>> On Wed, Aug 9, 2017 at 7:02 PM, Nahitchevansky, Georges
>> <ghn at kilpatricktownsend.com> wrote:
>>> Can we stop this back and forth on the same issue. A number of folks have told you they do not support a proposal to eliminate sunrise‎. So in mind I think we know what the positions are.  It is not helpful to keep re-hashing the same points. Can we just move on to discussing possible fixes  for the limited gaming issue as a separate topic.
>> Sometimes I have to wonder if some posts on this mailing list are some
>> form of parody, or whether they're actually serious. You already know
>> the answer, given the two posts earlier today:
>> http://mm.icann.org/pipermail/gnso-rpm-wg/2017-August/002304.html
>> http://mm.icann.org/pipermail/gnso-rpm-wg/2017-August/002307.html
>> Arguing about "stopping this back and forth on the same issue", in
>> light of an identical conversation must be a parody.....
>> As for the multiple +1s later, some folks might want to re-read the
>> message from May 5th:
>> http://mm.icann.org/pipermail/gnso-rpm-wg/2017-May/001949.html
>> "In particular, if you feel compelled to send a “+1” or “Agree”
>> message please just hit “Reply” and not “Reply All”. That way the
>> sender of the original message will know of your support without the
>> other 150-plus members of the WG having to take time away from their
>> other work.
>> We actually learned many new things today through the civil discourse,
>> exposing more cracks in the positions of those supporting sunrises.
>> These include two registry operator reps openly stated that a sunrise
>> policy is "moot" or "academic", since they'd implement one even if not
>> mandated. If anything, that demonstrates movement towards Jeremy's
>> proposal (indifferent to it being accepted), not away from it.
>> There's a long history of initial "majority" support for policies at
>> ICANN evaporating as more data/evidence is collected, and as positions
>> are more thoroughly scrutinized.
>> Just 2 quick ones:
>> 1. It was my analysis of the deeply flawed .biz/info/org contracts
>> (which would have allowed tiered pricing) that got them killed,
>> despite the father of the internet, Vint Cerf, disagreeing with the
>> impact of that analysis:
>> http://www.circleid.com/posts/icann_tiered_pricing_tld_biz_info_org_domain/
>> That analysis still rings true today, as new gTLDs exploit the
>> unlimited pricing power that they were wrongly granted in the new gTLD
>> program.
>> 2. IRTP-B PDP -- https://gnso.icann.org/en/group-activities/inactive/2012/irtp-b
>> In that PDP, I wasn't a member initially, but joined it after they
>> made a deeply flawed proposal regarding domain transfers. Due to
>> "group think", they came up with a ridiculous proposal called the
>> "ETRP", which would have allowed transfers to be undone within 6
>> months (which would have had enormous impacts on the secondary market
>> for domains). You can see my first substantial post to that PDP (after
>> my initial post) at:
>> http://forum.icann.org/lists/gnso-irtp-b-jun09/msg00301.html
>> I even openly pointed out the "group think"
>> http://forum.icann.org/lists/gnso-irtp-b-jun09/msg00332.html
>> I was so sickened at being ignored (despite being right) that I even
>> left the list:
>> http://forum.icann.org/lists/gnso-irtp-b-jun09/msg00425.html
>> however I continued to press the issue amongst stakeholders, and guess
>> what?!?!? The proposal was killed! Enough outrage was expressed by the
>> public (which I helped mobilize) in the comment period:
>> http://forum.icann.org/lists/irtp-b-initial-report/index.html
>> that the ETRP died on the vine. And, in that PDP, I was the *sole*
>> voice of opposition within that group to their proposal (having joined
>> it to expressly voice why it was flawed).
>> Now, I don't give these examples to aggrandize myself, but to point
>> out the historical broken processes appear to be repeating themselves,
>> when there are serious contributors to this PDP (not just myself) that
>> have a long track record of being right, even when it appears they're
>> in a minority (even a minority of just one). Go see the film "12 Angry
>> Men" as a more dramatic example.
>> The way to put forth stronger positions is to actually back them up
>> with facts and arguments, not just saying essentially "I'm not going
>> to be convinced by anything you have to say, so don't bother." That's
>> not consistent with evidence-based policymaking or even appropriate
>> debating tactics. Indeed, it's a form of a "tell" from those whose
>> positions are unable to withstand scrutiny, to make that sort of weak
>> "Please, say no more" statement.
>> So, here's some simple advice --- try putting yourself in the shoes of
>> the other person, to see things from their point of view! You might be
>> in a better position to see the weakness of your own arguments, or the
>> strength of theirs, and can then make adjustments to try to get a
>> strong consensus. Folks who've read my posts will note I've bent over
>> backward to attempt to curb cybersquatting (they're no friend of
>> mine), via balanced proposals.
>> Because, at the end of the day, this PDP has to produce reports that
>> survive wide *public* scrutiny, not just some "majority" that is
>> participating actively in this group. History has shown us that a weak
>> report can and will be savaged (it was kind of funny, after the ETRP
>> was savaged by the public, the remaining PDP members came begging for
>> my insights, which I graciously provided). [as an aside, don't expect
>> me to do an "Atlas Shrugged" post in this PDP -- this time, I'm not in
>> a minority of 1]
>> I'll conclude by saying to those who are "uncomfortable" by debate --
>> get used to it! Accept that weak positions and analysis will be
>> challenged. Rather than attempting to stifle those challenges, come up
>> with stronger arguments/facts.
>> Good night.
>> Sincerely,
>> George Kirikos
>> 416-588-0269
>> http://www.leap.com/
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