[Newgtld-input] Input on gTLD Batching
Rebecca.Berkich at xerox.com
Sat Aug 18 19:50:55 UTC 2012
To Whom It May Concern:
I am giving input on behalf of Xerox Corporation to address the batching
process for the new gTLDs. Transparency should be fundamental to each
step of the process.
Response to question #1 and #2.
Initial evaluation results should be posted for all applications at the
same time. All applicants should be notified at once whether or not they
passed Initial Evaluation, so they can immediately made decisions.
* Before the initial evaluation results are posted, ICANN should
hold a comment forum focused on generating feedback around the already
proposed registry agreement. These comments should be considered and
incorporated into a new and final registry agreement that will be
published along with initial evaluation results. This is an opportunity
for corporate attorneys to give feedback that could make finalizing
agreements more streamlined for everyone.
* Applications that must proceed to Extended Evaluation, are in
contention, or have received an objection should proceed through those
channels to resolve the roadblock.
* Those that are allowed to move on to the registry agreement
process should be given the Registry Agreement with feedback
incorporated. Then, as the applicants return the Registry Agreement to
ICANN (either edited, or not edited), ICANN should process the
agreements and, once the agreement is finalized, proceed with
pre-delegation testing on a First-In-First-Out (FIFO) basis through
using a time-stamp mechanism to process requests. Note that most gTLD
applications were made by large companies. The attorneys of those
corporations may likely cause some natural staggering during the
* When applications have passed all tests, they should be
inserted into a launch queue, again, on a FIFO basis.
* As applications move through the pre-delegation and launch
queue process, ICANN should provide complete transparency on where each
application stands through a publicly available online portal.
Xerox believes that following the above steps would allow transparent
processing of all applications and create a natural cadence that will
keep delegation below the 1,000 yearly limit and not cause upset and
unfairness through metering or other artificial prioritization. In
effect, ICANN would facilitate the batching process by allowing the
applicants themselves to control their placement. Proper batching,
metering, and smoothing can be achieved through the application process
already outlined within the Applicant Guidebook - namely, the process of
evaluation itself, the objection process, contention set procedures, the
actual registry agreement negotiation process and, ultimately,
transition to delegation. These existing elements, in conjunction with a
revised registry agreement, a FIFO policy will allow the program to move
towards the release of new gTLDs in a consistent, predictable, fair, and
Response to question #3.
Xerox applied for .xerox and .fujixerox and believes a neutral,
transparent, FIFO process levels the field between brand owners and
those companies who applied for new gTLDs purely for profit. Our gTLDs
were an investment in the future of Xerox and Fuji Xerox, and like many
companies, we want to leverage the advantages of our new gTLDs as soon
as possible. But since not all applications can get out of the gate
first, Xerox wants the entire batching process to be fair and
transparent for all applicants.
Thank you for opening up comments to the new gTLD batching process.
Manager, Search Marketing & Domains
Xerox Interactive Marketing
26600 SW Parkway, Mailstop 7060-630
Wilsonville, OR 97070
Tel: 503.685.4399 | 8*875.4399
rebecca.berkich at xerox.com <mailto:rebecca.berkich at xerox.com>
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