Draft BC position EOI
And with the paper ! _____ From: Philip Sheppard [mailto:philip.sheppard@aim.be] Sent: Tuesday, February 23, 2010 10:19 AM To: 'bc-gnso@icann.org' Subject: Draft BC position EOI For 14 day comment I have been asked by the new VP policy coordination Steve DelBianco to act as rapporteur for the issue of Expressions of Interest in the context of the new gTLDS process. I attach a proposed draft for the Constituency. Its argumentation and consequent conclusion is based on the submissions of Bc members in their individual capacity to the public comments process. These comment were significant in their commonality. In short all commentators believed that: - the EOI is a poor substitute for data gathering and an economic study - the EOI is bad business practice as it requires investors to invest in ignorance of issues that ICANN is obliged to solve. Comments, improvements are most welcome ideally by e-mail bullet points referencing the line numbers rather than Word tracked changes. This makes the job of the poor rapporteur much easier ! Philip
Dear Philip, Thanks for your efforts to pull this BC input on the EoI together. Here are a few comments for consideration: * Line 8 add "The BC appreciates that the EoI proposal will be discussed at the ICANN Nairobi meeting and encourages full consideration of all of the comments that have been submitted by individual BC members and the community" * Point 4 lines 55-69 suggest consideration of the following revised text "The EoI would require applicants to essentially invest blind, thus the ICANN Board should not implement any EoI proposal until the essential rules for the new gTLD application process are developed and agreed upon by the ICANN community. The BC does not believe that it is fair for ICANN to expect potential new gTLD applicants to engage in a mandatory EoI process, with limited terms by which any investment deposit may be refunded, while the rules for applications are not finalized. Key issues in these rules that must be finalized should be clearly identified by ICANN with the community, because it is not enough for potential applicants to rely on vague guarantees that key issues will be tackled and resolved. The current EoI proposal risks artificially inflating supply-side interest because it raises fears among many of being left behind. In summary, there are important unresolved issues, and the mandatory and irreversible model forces applications without sufficient understanding of potential future costs, which is not good business practice. We urge serious consideration of the impact of proceeding with such an EoI proposal given the state of the DAG and the negative consequences on business users. " Kind regards, Ayesha ________________________________ From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Philip Sheppard Sent: mardi 23 février 2010 10:25 To: bc-gnso@icann.org Subject: [bc-gnso] Draft BC position EOI And with the paper ! ________________________________ From: Philip Sheppard [mailto:philip.sheppard@aim.be] Sent: Tuesday, February 23, 2010 10:19 AM To: 'bc-gnso@icann.org' Subject: Draft BC position EOI For 14 day comment I have been asked by the new VP policy coordination Steve DelBianco to act as rapporteur for the issue of Expressions of Interest in the context of the new gTLDS process. I attach a proposed draft for the Constituency. Its argumentation and consequent conclusion is based on the submissions of Bc members in their individual capacity to the public comments process. These comment were significant in their commonality. In short all commentators believed that: - the EOI is a poor substitute for data gathering and an economic study - the EOI is bad business practice as it requires investors to invest in ignorance of issues that ICANN is obliged to solve. Comments, improvements are most welcome ideally by e-mail bullet points referencing the line numbers rather than Word tracked changes. This makes the job of the poor rapporteur much easier ! Philip
Thanks Philip. I agree with the paper, but would also like to see a statement to the effect that we believe an EOI process is more likely to delay the launch of the new gTLD program, for several of the reasons stated in our paper and also because this sort of public information is likely to cause preliminary disputes that may halt the entire program. Whereas on the other hand, if all the issues are worked out and the program begins, any disputes can be dealt with on parallel track while undisputed applications move forward unabated by those disputes. The paper should also mention the BC's longstanding support of the newTLD program, provided the 'overarching issues' are adequately addressed first. Best, Mike Mike Rodenbaugh RODENBAUGH LAW tel/fax: +1 (415) 738-8087 http://rodenbaugh.com <http://rodenbaugh.com/> From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Philip Sheppard Sent: Tuesday, February 23, 2010 1:25 AM To: bc-gnso@icann.org Subject: [bc-gnso] Draft BC position EOI And with the paper ! _____ From: Philip Sheppard [mailto:philip.sheppard@aim.be] Sent: Tuesday, February 23, 2010 10:19 AM To: 'bc-gnso@icann.org' Subject: Draft BC position EOI For 14 day comment I have been asked by the new VP policy coordination Steve DelBianco to act as rapporteur for the issue of Expressions of Interest in the context of the new gTLDS process. I attach a proposed draft for the Constituency. Its argumentation and consequent conclusion is based on the submissions of Bc members in their individual capacity to the public comments process. These comment were significant in their commonality. In short all commentators believed that: - the EOI is a poor substitute for data gathering and an economic study - the EOI is bad business practice as it requires investors to invest in ignorance of issues that ICANN is obliged to solve. Comments, improvements are most welcome ideally by e-mail bullet points referencing the line numbers rather than Word tracked changes. This makes the job of the poor rapporteur much easier ! Philip
participants (3)
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HASSAN Ayesha -
Mike Rodenbaugh -
Philip Sheppard