[Newgtld-input] Comment from eco Association of the German Internet Industry

Thomas Rickert rickert at anwaelte.de
Sun Aug 19 13:39:50 UTC 2012

The below comments are made on behalf of eco, the Association of the German Internet Industry (www.eco.de). eco is the German Internet Industry Association with about 600 members from different Internet industry sectors. The association represents over 200 ISPs and Registrars as well as Registries.

First of all, ICANN should take all reasonable steps to increase the speed of evaluating all applications. There are synergies arising from the limited number of Registry Service Providers, which lead to partially congruent responses to the technical questions. Applicants that have applied for multiple strings may have used partially congruent information in business plans etc. Hence, the evaluation process can be streamlined without any loss of quality by identifying the variations and determining their impact on the overall assessment. Where possible, applications should be assigned to evaluators in a manner that allows for the common evaluation of substantially similar applications.

We also believe that there will be a natural sequencing after the publication of the results of the initial evaluation for all applications due to objections, withdrawals, GAC Advice and contentions, but also due to factors beyond ICANN's control since applicants need to return signed contracts and also apply for the delegation, which provides for additional sequencing. 

Additionally, all applicants should be given the opportunity to opt for their TLD being delegated at a later stage. ICANN should consider to offer financial incentives for those who opt out.

Secondly, the ICANN Community has been advised that the effects of delegating new TLDs into the root zone will be monitored and analyzed. ICANN should seek more information on how this process is envisaged by the technical experts. How many TLDs will they allow to be delegated at first? Will there be a pause for analysis afterwards? How long might such pause be? What will be the sequence of delegations afterwards?
ICANN should synchronize its metering with the plans of the technical experts, if possible.  

Should additional metering be needed, the sequence should be as follows:

The absolute majority of eco members that have contributed to this comment are in favor of giving preference to geoTLDs, IDNs and community TLDs..

All applicants will be sent the contracts for execution at the same time, unless their application requires an extended evaluation. Natural sequencing in contract negotiation and execution as well as applying for delegation will provide for natural sequencing.

Afterwards, non objected TLDs will be handled in the same manner, unless there is GAC Advice, extended evaluation or a contention.

After that, those who opted out will be handled in the same manner, unless  there is GAC Advice, extended evaluation or a contention.

For cases where there is GAC Advice, an extended evaluation or a contention, the handling will occur as the cases are resolved.

Thomas Rickert, Attorney at Law
Director Names & Numbers

eco - Verband der deutschen Internetwirtschaft e.V. / Association of the German Internet Industry

Lichtstraße 43h
50825 Köln

Fon:    +49 (0) 221 - 70 00 48 - 0
Fax:    +49 (0) 221 - 70 00 48 - 111
E-Mail: thomas.rickert at eco.de
Web:    http://www.eco.de


eco - Verband der deutschen Internetwirtschaft e.V.
Geschäftsführer: Harald A. Summa
Vorstand: Prof. Michael Rotert (Vorsitzender), Oliver Süme (stv.
Vorsitzender), Klaus Landefeld, Thomas von Bülow, Felix Höger
Vereinsregister: Amtsgericht Köln, VR 14478
Sitz des Vereins: Köln

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