[Newgtld-input] United TLD's response to ICANN"s request for community input on batching / metering

[Dave Panos]

Thank you for the opportunity to provide input into gTLD batching. We value
ICANN’s approach to openly soliciting feedback about this critical element
of the new gTLD process.

United TLD Holdco Ltd has submitted 26 applications for the new gTLD
program.  We participate in the Registry Stakeholder Group as an Observer
and also as an active member of the New gTLD Applicant Group (NTAG).

We are firmly in support of NTAG’s nine-point document to ICANN on this
topic and voted in favor of it. The points made about initial evaluation
timing, metering/sequencing, contention sets, objection period, GAC
feedback, pre-delegation testing, contracts, root scaling and transparency
are really critical to getting the process moving and restoring credibility
to ICANN's new gTLD program.

In addition to the consensus view of NTAG, United TLD provided input and
feedback to the extensive document on sequencing and metering that was
submitted by Google and other community members. We want to go on record
with ICANN that we are strongly in support of the philosophy, principles
and approach of that document, with just one exception. We do not agree
that special categories or buckets of applicants should be created and used
to weight the sequencing order. We believe that any attempt to bucket
applications, beyond the geographic distribution that ICANN initially
selected for digital archery, needlessly and unfairly attempts to assign
higher merit to certain types of TLDs. This is a very slippery slope, and
ICANN should not be in the business of categorizing or assigning merit to
applicants on any basis.

In response to question #3 of your request for community input on batching,
regarding the level of importance that the order of evaluation and
delegation has for our applications -- we assert that the order of
application evaluation and gTLD delegation is of critical importance to
each of our 26 TLDs. Each of our applications specifies our intention to
operate the associated gTLD as an open name space with the expectation of
broad usage by many different registrants. Therefore our gTLDs will be
subject to the broadest range of competitive pressure from existing and new
gTLDs.  Time-to-market, sequencing relative to competitive gTLDs and
visibility into timing are paramount to the successful launch and
development of our gTLDs.

ICANN has both the capability and the responsibility to do much, much
better than the timetable published on August 17th. It is our belief that
ICANN significantly misread the sentiment behind  "one large batch" in
Prague. It was far from a consensus point of view, and where it was
espoused, it was with a strong expectation that ICANN would realize massive
efficiencies from a far more homogenous applicant pool than anyone
expected. Nobody dreamed that a timetable would come back where initial
evaluation results wouldn't be published until more than a year after the
application window closed. The community is shocked by your timetable.

It is our great hope and expectation that ICANN will challenge itself to
rebound from the series of missteps that have characterized the past five
months. Now is the time to rise to the occasion and opportunity presented
by the new gTLD program.  The community has worked diligently over the past
few weeks to arrive at substantive postions and approaches with broad
participation and support -- this is visible in both the NTAG and Google
submitted documents. You have received the community input needed to
reorganize the program and get it back onto a winning path. It's time to
adopt that input and get serious about operational excellence again.

Respectfully yours,


Dave Panos

Director

United TLD Holdco, Inc.