September 2018 - comments-gtld-subsequent-procedures-initial-03jul18@icann.org

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments of the United States Postal Service on the Subsequent Procedures Initial Report
by Aikman-Scalese, Anne Sept. 26, 2018

Sept. 26, 2018

Attached please find the comments of the United States Postal Service on certain portions of the Subsequent Procedures Initial Report. Thank you, Anne Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman(a)lrrc.com<mailto:AAikman@lrrc.com> _____________________________ [cid:image003.png@01D455AB.D9F46C70] Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com/> ________________________________ This message and any attachments are intended only for the use of the individual or entity to which they are addressed. If the reader of this message or an attachment is not the intended recipient or the employee or agent responsible for delivering the message or attachment to the intended recipient you are hereby notified that any dissemination, distribution or copying of this message or any attachment is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the sender. The information transmitted in this message and any attachments may be privileged, is intended only for the personal and confidential use of the intended recipients, and is covered by the Electronic Communications Privacy Act, 18 U.S.C. ?2510-2521.

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments from Christopher Wilkinson
by wilkinson christopher Sept. 26, 2018

Sept. 26, 2018

PDP Subsequent procedures on the next Round of applications for new gTLDs. Comments from Christopher Wilkinson The following comments address general issues that have arisen in the PDP. More detailed responses to the questions included in the Annex to the Initial Report will be presented by ALAC, with which I am in agreement, and on a few details I have contributed. This personal comment does not qualify or amend in any way the ALAC response. 1. Institutional standing of a GNSO PDP within the ICANN community: In spite of significant difficulties arising from GNSO positions taken in 2007 and subsequently, the incumbent representatives of GNSO maintain their 'right' to conduct this PDP as a GNSO entity under GNSO rules. This position is quite problematic. (a) GNSO is still dominated by DNS industry participants, notably Registries, Registrars and Intellectual Property interests. Absent effective counterbalancing from other SO/ACs, GNSO would appear not to be like a multi-stakeholder self-regulating body, but rather like an DNS industry cartel. (b) We have been repeatedly told that the status of GNSO is as the only entity able to develop policy for gTLDs, and that this is protected in the ICANN Bylaws. If this is indeed the case, then either GNS needs to be reformed, or the Bylaws need to be changed. 2. Working methods of the PDP: The PDP divided its scope into several 'Work Tracks' (1-4). Each WT has contributed extensively to the Initial Report (which is in and on itself a substantial achievement). However there has been little work on the mutual consistency of the several texts arising from each of the Work Tracks. Indeed, the PDP has been repeatedly informed that the purpose of PDP review of WT drafts has been to establish whether the texts reflect accurately the work of the WT. Nothing more. And that PDP members who had comments on the WT texts should address, not the PDP, but the present public comment procedure. The net result is that the current Initial Report is a rather 'raw' text and does not contain the comments, improvements and corrections that other PDP members would have been able to provide. 3. Geographical Names and the special case of WT5: Work Track 5 was set up belatedly to address issues related to Geographical Names, on a cross-community basis. So far so good. However, as a sub-group of the PDP, WT5 is still subject to the GNSO PDP rules. It remains to be seen how this will work out in practice. In other respects, WT5 is not a subject for the present pubic consultation and will benefit from a separate report and - presumably – an additional public consultation in due course. 4. The Economic and market context for the new gTLD programme: AS far as one can see, ICANN does not benefit from any systematic measurement and analysis of the DNS markets. Whether their size, structure, languages, growth-rates (or not), and their consequent capacity to absorb the services of new gTLDs. This lacuna has been pointed out to ICANN on several occasions over the past twenty years. Cursory inspection of the results of the 2012 Round suggests that rather too many new gTLDs were authorised, all at once, indeed more than the DNS market could absorb at that time. There is no assurance that the next rounds will be any better off in this respect. ICANN should take this matter in hand. Note that (a) ALAC will recommend that there is no urgency to open additional rounds, and (b) there is strong support for managing future rounds in batches of applications. Note, also, that the apparent short term saturation of the DNS market, applies particularly to generic strings in the English language, whereas most of the recent growth in the Internet has been in non-English speaking countries. The rationale for this bias escapes me, it may well have contributed to the modest performance of new gTLDs from the last round.. 5. Competition and diversity: The PDP Initial Report confirms that the 2012 Round resulted in a few entities accumulating significant numbers of nes TLDs and technical (back-end) Registry services. It would appear that the degree of concentration that has taken place in the DNS market was facilitated by the flawed decision in 2010 to rplace a policy favoring vertical integration between new independent Registries with a policy favoring cross-ownership between Registrars and Registries. The economic consequences of that decision may be qite far-reaching and should be re-considered by iCANN. * * * CW/ 26 September 2018.

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[Comments-gtld-subsequent-procedures-initial-03jul18] LEMARIT's comments on the Working Group Initial Report
by lrs Sept. 26, 2018

Sept. 26, 2018

Dear New gTLD Subsequent Procedures Working Group team, Please see attached LEMARIT's comments and suggestions on the Working Group Initial Report. Thank you very much for all the work you have done, it is highly appreciated. Best regards, Neli Marcheva and Zornitsa Marcheva

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[Comments-gtld-subsequent-procedures-initial-03jul18] RySG comments on SubPro Intitial Report
by Paul Diaz Sept. 26, 2018

Sept. 26, 2018

On behalf of the gTLD Registries Stakeholder Group (RySG), please find attached our input on the "Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)." In the interest of time, we did not conduct a vote on these comments. We did discuss them extensively on our mailing lists and during several biweekly conference calls, and no member opposed their submission. Feel free to contact me with questions or concerns. Best, P Paul Diaz Chair, RySG

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comment re: Initial Report on the New gTLD Subsequent Procedures Policy Development Process
by John Poole Sept. 26, 2018

Sept. 26, 2018

Attached (pdf) is my comment (response and feedback) to the Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4). If any questions, contact me. Respectfully submitted, John Poole, registrant &* editor, *DomainMondo.com

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[Comments-gtld-subsequent-procedures-initial-03jul18] FairWinds Partners' Comment on the New gTLD Subsequent Procedures PDP Initial Report
by Lillian Fosteris Sept. 26, 2018

Sept. 26, 2018

Please find FairWinds Partners’ comments attached. Best, Lillian Fosteris -- Lillian Fosteris I FairWinds Partners I Washington, D.C. Office: (202) 499-4107 I Mobile: (202) 657-8223 I lillian.fosteris(a)fairwindspartners.com<mailto:lillian.fosteris@fairwindspartners.com>

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments submitted on behalf of the ICANN Board
by Wendy Profit Sept. 26, 2018

Sept. 26, 2018

Please find attached comments submitted on behalf of the ICANN Board regarding the New gTLD Subsequent Procedures WG Initial Report. Thank you, Wendy Profit ICANN – Senior Manager, Board Operations 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments from .UY ccTLD
by Monica Soliño Sept. 26, 2018

Sept. 26, 2018

.UY believes that the technical questions asked by the GNSO Working Group need to be addressed and answered by the SSAC, two-character strings, consisting of one letter and one digit, or two digits, should unequivocally not ever be permitted in future gTLD application rounds because of the conflict with ccTLD allocation policy and ISO two-character codes (which are external to ICANN), as well as the homographic issues discussed above. -- ---------------------------------------- Mónica Soliño Adminstración del Dominio .UY SErvicio Central de Informática (SECIU) Universidad de la República Colonia 2066, Montevideo 11200, Uruguay Telef. (+598) 2408-3901 FAX (+598) 2401-5843 https://www.nic.uy ----------------------------------------

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[Comments-gtld-subsequent-procedures-initial-03jul18] Neustar comments on New gTLD Subsequent Procedures PDP WG Initial Report
by Austin, Donna Sept. 26, 2018

Sept. 26, 2018

Please find attached Neustar's comments. Donna Austin Neustar, Inc. / Senior Policy Manager, Registry Solutions Mobile: +1 310 890 9655 donna.austin(a)team.neustar<mailto:donna.austin@team.neustar> / Website: home.neustar<http://www.home.neustar/> Follow Neustar: LinkedIn<http://www.linkedin.com/company/5349> / Twitter<http://www.twitter.com/neustar> Reduce your environmental footprint. Print only if necessary. ________________________________ The information contained in this email message is intended only for the use of the recipient(s) named above and may contain confidential and/or privileged information. If you are not the intended recipient you have received this email message in error and any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately and delete the original message.

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[Comments-gtld-subsequent-procedures-initial-03jul18] INTA Comments
by Lori Schulman Sept. 26, 2018

Sept. 26, 2018

I am pleased to submit INTA's comments. We thank the Working Group and ICANN Staff for their continued efforts to improve the new gTLD application process. If I can provide further information, please do not hesitate to contact me. Lori Schulman Senior Director, Internet Policy International Trademark Association 1250 Connecticut Avenue, Suite 700 Washington DC, USA +1-202-704-0408, skype: lsschulman www.inta.org<http://www.inta.org/> Find us on: [Description: Description: Description: cid:F361C18F-02FE-4CF0-A43E-AA8566DC2514] Twitter<https://twitter.com/INTA> [Description: Description: LinkedIn] LinkedIn<http://www.linkedin.com/groupInvitation?groupID=69899> [Description: Description: facebook-logo (2)] Facebook<http://www.facebook.com/home.php?#!/GoINTA?ref=ts> [Description: Description: pnpb_sig.png]

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