Dear Christopher, thank you for your comments. Please be so kind to find my comments inline: On 26/08/2016 23:53, CW Mail wrote:

Dear Olivier:

I regret that I was not aware that this activity had been going on during the past year. Actually, I do not understand the rationale for conducting a 'market health' activity in parallel with the CCCT review. They both address the same underlying issues.

Yes and no. The CCCT review is a review that looks at the program as a whole and sees whether it has delivered what it promised to deliver. The Marketplace Health Index is a program implementation based on the CCCT review's prior work.

Regarding the proposed metrics, I am rather perplexed. Interesting as they may be, they do not address any of the fundamental measurements of 'market health'. Rather, we need to be looking at some basic - indeed classic - measurements of market performance (most of which are already reported to national statistical authorities), such as:

1. Financial turnover in recent years (e.g. last 5 years) of Registries and Registrars, normalised to a common exchange rate. Distinguish existing and new Registries and Registrars.

Frankly I do not know how that would be obtained bearing in mind the significant number of Registries and Registrars that operate in jurisdictions or have an operational vehicle that do not mandate for the publication of audited accounts.

2. Market share data; degree of concentration or competition, rate of penetration of the 'new' gTLDs since they were launched. How have new gTLD registrations been financed?

The first part of your suggestion is, I think, covered by the proposed ALAC comments made under "Competition", where we ask for the share of the market. As for the second part, how have new gTLD registrations been financed, how would you suggest this be found considering ICANN has absolutely no visibility over this?

3. Investment data: how much has been invested in the creation of new gTLDs; how much is invested by existing gTLDs. How was the investment financed?

Again - where would this data be found when a significant number of actors operate without being required to submit such data?

4. Employment data: How many people work in this new industry? Distributed by Registries and Registrars. Distinguish existing large, medium sized entities and new gTLD entrants. Distributed by geographic area.

Again - how? I don't even think that the DNA (Domain Name Association) knows this.

5. Trade Data: We are looking at a branch of international trade in IT services. What proportion of existing and new turnover of Registries and Registrars derives from domestic (national) business and from international business (e.g. Registry business with Registrars in third countries and registrations by registrants in third countries.)

I agree that this would be very helpful, but how would this data be gathered? Kindest regards, Olivier