[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on Initial Report on the New gTLD Subsequent Procedures Policy Development

[Alexander Schubert]

All comments made by Alexander Schubert, Riga, Latvia in his personal
capacity. Co-founder of .berlin and active participant in several work
tracks.

 

 

*         In 2.5.1.c.2:  I assume "principal" should be "principle"?



*         In 2.5.1.e.4: Are there policy, economic, or other principles or
factors that might help guide the establishment of the floor amount?

As we will most likely see several more rounds before we switch to continues
application mode and as by the start of the next round about 8 to 9 years
since the 1st round have gone by there will be a very high demand in
applications.
In order to keep that amount manageable and in order to prevent an
application stack that would take 2,3 or maybe even 3 years to work off it
would be only natural to keep the application fees for the coming round
HIGH. The results would be:

*         A manageable application stack (ideally to be processed within a
year, so the next round could start a year later)

*         Less speculative registrations (less warehousing)

*         Speedy processing for all applicants (no risk, that an application
might be at the end of a long stack)

The application fee floor could be slowly lowered round by round - adapting
to the amount of applications of the previous round

I suggest an application fee of 500,000 USD in the next round: If that
should yield to only 100 or less applications; no problem as the following
round would come up within a few month then (short application stack, speedy
processing)
Sadly in our current world seemingly a financial barrier is the only real
working barrier. And absent a high entry barrier we will be FLOODED with new
gTLDs - which eventually renders the DNS senseless

 

*         2.6.1: Application Queuing (WT2) - general remark (if has to be
tied with a question then 2.6.1.e.3):

o   The entire "application queuing" came only up as way more application
were submitted than expected. THIS time we do KNOW that we have to queue! So
why not simply including that task into the application process?

*  Any entity that doesn't wish speedy processing would indicate already at
submission of the application. 

*  Every application will receive a random (many digit long) "queueing
number" assigned by the application system (yes: computers can create RANDOM
numbers, since decades already)

*  The applications are then queued by these numbers

*  Absolutely no need to start hilariously complicated processes like
"auctions"

 

*         2.6.1.e.4:

o   CAUTION with statements like "those from the Global South should be
prioritized". In other words if portfolio applicants use "global south" tax
havens (like Seychelles) instead of the Caribbean: they get prioritized? We
live in a globalized world: the applicant entities can be positioned
ANYWHERE on the globe!



*         2.6.1.c.4:

o   Absolutely RIDICIOUS thought. Why granting portfolio applicants EXTRA
PERKS? Doesn't make ANY sense at all. Who comes up with such heinous
thoughts? Why would we create BENEFITS for portfolio applicants? I thought
the goal was to PREVENT "warehousing"? So NO: There is no cherry picking in
the queueing process within several applications from one applicant. 



 

Thanks,

 

Alexander Schubert

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