[Newgtld-input] Input on gTLD Batching

Mon Aug 20 07:37:26 UTC 2012

Dear Sirs,

We would like to declare our support for the proposal of TLDDOT GmbH (.GmbH
Top-Level-Domain):

Quote start:

Bethink of the Global Public Interest

When it comes to a batching procedure ICANN needs to bethink on its mission,
core values and the global public interest and not fall for the portfolio
applicants line.

It is highly inconsistent to value all applications the same through the
batching/sequencing process. ICANN has already valued Geographical Names,
Communities (except of strings which have been applied for to use as brand
or company name) and IDNs differently by attributing a higher weight to them
than Standard gTLDs, giving them special categories within the Applicant
Guidebook, while also adding restrictions and other requirements to them.
This valuation has been agreed upon by a multi-stakeholder consensus within
the global Internet Community and cannot been annulled by portfolio latest
sequencing ideas. The goals were to give Internet users more choice, support
their language and to protect communities' of high semantic meaning on the
Internet. The achievements of the new gTLD program will be also measured
against these goals.

Sequencing all gTLD applications in the same manner would compromise these
achievements and differences by valuing generic gTLDs such as .BET, .CLICK
or .CASINO in the same way as supported public interest gTLDs such as
.PARIS, .IEEE or .ORG in Chinese characters.

It is unfair to single applicants, especially the ones without a portfolio
of gTLD strings to swap slots (rich applicants pay poor applicants to step
back towards a later evaluation/approval date). This mechanism favors the
interest of portfolio applicants, who have a greater chance of gaining
advantage from this mechanism on average than single applicants. This would
compromise what ICANN should represent, especially if it does not take
diversity into consideration or take smaller single applicants more
seriously or into account. We are strictly against any mechanism which
involves money for swapping slots.

Withholding applications for Geographical Name, Community and IDN gTLDs
until all other applications have been processed might appear to some
stakeholders that  ICANN does not work in the global public interest, an
important and critical part of its mission. The Geographical Name, Community
and IDN gTLDs are mostly supported by governments and large communities and
are truly in the global public interest.

In order to follow ICANN's request to answer specific questions we would
like to comment as follows:

Should the metering or smoothing consider releasing evaluation results, and
transitioning applications into the contract execution and pre-delegation
testing phases, at different times?

No, since according to the timeline all applications will be released in
May/June 2013, which is app. one month after the GAC Advice, we do not see
the necessity to establish a new process.

How can applications be allocated to particular release times in a fair and
equitable way?

A fair and equitable way would be to delegate applications in an order that
serves the public interest. Such an order should prioritize uncontested
applications that have a special public interest status such as a)
Geographical Name, b) Community or c) IDN (all together only 242 gTLDs). The
sequencing for delegation should follow a round-robin process per ICANN
region. 

An advantage of processing these categories first is that the adherent
direct contention sets (at least 107 applications = 1 Geographical Name, 1
IDN, 105 community) are likely to be solved early in the process.

As a second step an ICANN region based round-robin should be conducted with
uncontested applications from single applicants and portfolio applicants who
can choose one string as their preferred one, assuming this string has
neither objections nor contention.

The round-robin will be continued as long as necessary. Applications in
extended evaluation, objection, contention and with GAC interaction will be
added to the round-robin pool as soon as their objection and/or contention
has been completed.

Would this approach provide sufficient smoothing of the delegation rate?

Our described approach would not only serve the public interest and take the
interests of all applicants into respect, it would also allow creating new
gTLD success stories for ICANN. Such events are needed to reinforce public
interest, trust and reliability in ICANN and are according to ICANN's
mission.

Should the metering or smoothing be accomplished by downstream metering of
application processing (i.e., in the contract execution, pre-delegation
testing or delegation phases)?

This is a question of facilitating efficiencies in the applications process.
The RySG/NTAG group provided guidance on the efficiencies issue which we do
not want to echo in detail here. However, with the proposed public interest
prioritization and followed by a round-robin method we do not expect any
further necessity to downstream delegation rates.

Keeping the said above in mind all applicants should be asked if they want
to "opt out" with the consequence of being initially evaluated at a later
stage. This could significantly decrease the number of applications to be
reviewed ASAP.

Include a statement describing the level of importance that the order of
evaluation and delegation has for your application.

Most Community-based gTLD strings are very well accepted and popular new
gTLD strings, this is common opinion within the ICANN community including
GAC. In terms of business planning an early approval of Community-based gTLD
strings is likely to contribute to a maximum economical and political
success of the New gTLD program and ICANN's reputation as well.

Quote end.

When it comes to these two points we have a slightly different view:

How can applications be allocated to a particular timing in contract
execution, pre-delegation testing, or delegation in a fair and equitable
way?

ICANN should release competing TLDs at the same time to ensure equal
time-to-market. Non competing TLDs can be released at will, whenever they
are ready to be delegated.

Provide reasoning for selecting this approach.

ICANN should try to avoid discrimination of TLD in the delegation process.
This would be the case when one TLD is released while another one with the
same target audience is not released for no good reason.

eom

With best regards,

DocCheck AG
Philip Stadtmann
Head of Finance & Controlling
Vogelsanger Str. 66
50823 Cologne

Germany
fon: +49.221.92053-149
fax: +49.221.92053-133
mailto: <mailto:philip.stadtmann at doccheck.com> philip.stadtmann at doccheck.com
home: <http://www.doccheck.ag/> www.doccheck.ag

Trade Register Cologne HRB 32420
Executive Board: Dr. Frank Antwerpes (Chairman), Helmut Rieger
Chairman of the supervisory board: Michael Thiess

Please note our  <http://www.doccheck.ag/index.php?id=389> Disclaimer. 