[Comments-new-gtld-auction-proceeds-initial-08oct18] .Club Domains, LLC Comment in Support of a Global Awareness Campaign (Text Version)
jonathan at get.club
Wed Nov 21 18:52:51 UTC 2018
*.Club Domains, LLC Comment on the Top Level Domain (gTLD) Auction Proceeds
Cross-Community Working Group Initial Report*
November 20, 2018
ICANN has published the Initial Report (Initial Report) of the Top Level
Domain (gTLD) Auction Proceeds Cross-Community Working Group (CCWG).
<#_ftn1> We hereby present a specific proposal that supports ICANN and the
stakeholders of ICANN. In addition, we address our specific responses to
the CCWG Clarification Requests.
*I. **The Auction Funds Global Awareness Campaign Proposal*
We propose that ICANN should earmark a portion—15% of the total auction
funds—to support an education campaign to promote Universal Awareness of
the uses of the Domain Name System and all TLDs in general. The
Board-Approved 2011 Global Awareness Campaign <#_ftn2> can be extended
and used as a model (see II a. below). This has the advantage of ensuring
that the plan is within the scope of ICANN’s mission, bylaws and tax
status, and builds on the work done by the previous group.
The Auction Proceeds Global Awareness Campaign should incorporate the
following themes from the 2011 Global Awareness Campaign, which the ICANN
Board has already vetted and approved:
· “consumers and end-users [should be the] primary target” (2011
Global Awareness Campaign).
· “gTLDs are a platform [as a] innovation.” (2011 Global Awareness
· “The landscape of the Internet is changing” (2011 Global Awareness
· The “promotion of competition in the domain name market while
ensuring Internet security and stability.” (2011 Global Awareness Campaign).
· The Auction Proceeds Global Awareness Campaign should not favor
any single TLD, to the exclusion of the others, in alignment with the 2011
Global Awareness Campaign recognition of its “role as stewards, not
advocates” and therefore being “neutral”. This follows the CCWG
recommendation that “Projects should avoid “marketing” any particular
option, but help to highlight how the DNS works, and how to use a domain
We propose that a steering committee of diverse backgrounds be formed of
qualified members from the ICANN community who would be tasked to craft an
RFP that would serve to hire a qualified professional agency to create and
execute a Global Awareness Campaign. The Auction Funds designated for
global awareness should be allocated to cover the costs of such an agency
and all media spending subject to the guidance and approval of the Steering
Committee. The funds should be designated for expenditure over three
years. This has the advantage of allowing for testing and pilot programs to
ensure the funds are utilized to create an Awareness Campaign with the
II. *Responses to the CCWG Clarification Requests*
This section addresses the CCWG’s previous work and discussion of an
awareness campaign. In the November 16, 2017 meeting, the CCWG raised two
important questions regarding use of the Auction Funds to support a Global
Awareness Campaign. 1) Would such partial allocation be within the scope
of the ICANN Mission & Bylaws; and 2) would such an awareness campaign be
consistent with ICANN’s integrity.
According to the Initial Report, the following clarifications were
· A Global Awareness Campaign was categorized as “Examples to be
further considered by CCWG – certain parts may be consistent while others
may not.” (Initial Report).
· *“*A legal investigation is needed, whether [a Global Awareness
Campaign] is within scope of ICANN’s mission and Bylaws. (Initial Report).
· Are we violating ICANN’s integrity? (Initial Report).
*a. **Allocation of a portion of the Auction Funds to support a Global
Awareness Campaign is clearly not outside the scope of ICANN’s
Mission/Bylaws because the ICANN board already approved a gTLD awareness
campaign in 2011 that was to target the Domain Industry, Registrants, and
There is no question that an education campaign about the gTLDs and the
nature of the DNS falls squarely within ICANN’s Mission under the Bylaws.
In fact, the ICANN board has already approved a gTLD Global Awareness
Campaign, “On 20 June 2011, ICANN's Board approved a program that will add
to familiar top-level domains such as .com, .org, and .net, the possibility
of having almost any word in any language as a top-level domain. This
massive expansion of the number of possible domain names calls for an
equally significant communications campaign to raise global awareness about
the program. “
The 2011 Global Awareness Campaign provided for consumers to be targeted
for awareness of the gTLDs. “[N]ew domains must first be available before
end-users can reap the benefits. It is the entities that apply for and
implement new gTLDs that will pass on the benefits to the end-user”
(Emphasis Added, Page 3, 2011 Global Awareness Campaign). Moreover, the
board expected that the “consumers and end users” would be targeted after
the new gTLDs became available. It is unclear why ICANN has not followed
through on the board directive to initiate a Global Awareness Campaign
aimed at consumers and end-users, but this is an opportunity to follow
Additionally, the 2011 Global Awareness Campaign envisioned a “Coordinated
campaign incorporating TV, radio, print and online advertising elements,
customized by region. Initial advertising targets: international business
TV, newspapers and websites, Google ads. Develop an energetic, bright,
attention-getting teaser campaign – both in video and print form - that
piques interest and directs people to the new gTLD website.” (Page 4, 2011
Global Awareness Campaign).
The 2011 Campaign was in alignment with the CCWG recommendation
that any awareness campaign be neutral, so as to maintain ICANN’s
integrity. “Recognizing our role as stewards, not advocates, we will be
neutral, presenting all sides of the issue while still promoting the great
work done by all who participated in crafting the program.” (Page 2, 2011
Global Awareness Campaign). Additionally, the existence of the 2011 Global
Awareness Campaign serves to answer the CCWG’s question of whether an
awareness campaign would be compatible with ICANN’s integrity.
*b. **The Transcript of the November 16, 2017 CCWG Meeting indicated
that the Global Awareness Campaign would remain in play, although the
Initial Report was ambiguous, and sometimes contradictory.*
The CCWG Initial Report unfortunately omitted the support from the
contracted parties house of the GNSO. In response to concerns which were
posed from the business constituency and the ALAC, it was noted that “I
have a hard time understanding why [the Global Awareness Campaign] would
not be included in the mission when we're talking about an awareness
campaign or perhaps a new round in developing areas to apply [for] a
top-level domain when the Applicant Guidebook which is the source of this
funding actually uses that as an example for potential uses. So while we
may or may not agree that that’s a good use[,] I don’t see how we could
agree that it's not an acceptable use under the mission of ICANN. Thank
you.” To which the moderator responded: “Agree. That’s why we are not
deleting it but we're putting it with a comment on the right column to the
very end or we keep it where it is.” (CCWG Meeting Transcript from
November 16, 2017).
Thus, the CCWG transcript indicated that proposal 12 was to remain in play,
with a clarification request about whether a Global Awareness Campaign
would be within ICANN’s mission. Based on the fact that a Global Awareness
Campaign supports ICANN’s mission of Global Acceptance & supporting the
interoperability and openness of the DNS, and the ICANN board has already
approved a Global Awareness Campaign in 2011, the CCWG’s mission concerns
should be answered affirmatively, that the use of the Auction funds is
squarely within ICANN’s mission and the plain language of the ICANN Bylaws.
*Taking all of the above into consideration, and especially the fact that a
Global Awareness Campaign has already been approved by the ICANN Board, we
strongly urge the CCWG to consider our proposal and recommend the
establishment of a Steering Committee and the allocation of 15% of the
auction proceeds toward the above-referenced Global Awareness Campaign to
be managed by said Steering Committee.*
We thank the ICANN Board, the CCWG, and the community for the opportunity
to comment on the Initial Report and to contribute to answering some of the
questions that the CCWG has raised.
 <#_ftnref2> https://www.icann.org/news/announcement-2011-07-05-en
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