[Comments-subsequent-procedures-22mar17] Canadian Internet Registration Authority (CIRA) Comment Submission on New gTLD Subsequent Procedures

[Richard Schreier]

CIRA is pleased to submit the attached comments with respect to ICANNs invitation to comment on the New gTLD Subsequent Procedures.  Our comments focus on a number of specific areas:


-       Encouraging the creation of a registry certification program operated and funded independently of the gTLD application process



-       Recommending a reduction in the application fee considering the reduced evaluation requirements an RSP program would provide, the limited need for a legal set-aside and a clear surplus from the first round.  We believe a reduced fee would lower the barrier to entry and allow geo-based applicants (who are typically publicly funded) to pursue their own platform



-       A further recommendation to create a tiered pricing model for variable fees particularly as related to minimum charges.  Small brands and geo-based Registry Operators see the current annual minimum of $25KUSD as a real barrier to entry.



-       We also would hope that ICANN would pursue the next "round" (or acceptance of applications) sooner rather than later especially as applied to brand and geo-applicants.


Regards

Richard Schreier
Product Manager
Canadian Internet Registration Authority (CIRA)
Tel: (613) 237-5335 x222 | www.cira.ca<http://www.cira.ca/>
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