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

[Comments-gtld-subsequent-procedures-initial-03jul18] RrSG Response to Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)
by Zoe Bonython Sept. 26, 2018

Sept. 26, 2018

Hello, On behalf of the Registrar Stakeholder Group (RrSG), I’d like to submit the attached response to the 'Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)’. Kind regards, Zoe Bonython RrSG Secretariat

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[Comments-gtld-subsequent-procedures-initial-03jul18] SIDN comments on 1 letter - 1 digit domains
by Maarten Simon Sept. 26, 2018

Sept. 26, 2018

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[Comments-gtld-subsequent-procedures-initial-03jul18] NIC Costa Rica (.cr) Comments Regarding the Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group (Work Track 1-4)
by Rosalía Morales Sept. 26, 2018

Sept. 26, 2018

To Whom It May Concern, Attached please find NIC Costa Rica’s comments in regarding the Initial Report of the New gTLD Subsequent Procedures Policy Development Process (PDP) Working Group (Work Track 1-4). Best, Rosalía [cid:3458ec5a-7faf-4912-9377-c4dea55797df@namprd14.prod.outlook.com]

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments by XYZ
by Grant Carpenter Sept. 26, 2018

Sept. 26, 2018

*XYZ’s COMMENTS ON THE initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)* XYZ was an active participant in the 2012 round and is now the registry operator of ten TLDs. With its significant experience in the space, XYZ offers the following comments on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4). *--Overarching Issue 2.2.3 - Applications Assessed in Rounds--* XYZ agrees with The Working Group’s recommendation that the next introduction of new gTLDs shall be in the form of a “round.” Following such a round, XYZ is strongly against 2.2.3.d.4, 5 and 6, which each involve permanently opening up a first-come, first-served process of new gTLD applications. The future supply and demand for additional new gTLDs is currently too hard to predict and an indefinite opening up of the supply could potentially crash the whole market. Accordingly, XYZ recommends any of 2.2.3.d.1, 2, 3. *--Overarching Issue 2.2.5 - Application Submission Limits--* XYZ agrees with the Working Group that there are no effective, fair and/or feasible mechanisms to enforce such limits and therefore no limits should be imposed on either the number of applications in total or the number of applications from any particular entity. *--Overarching Issue 2.2.6 - Accreditation Programs (Registry Service Provider Pre-Approval)--* XYZ strongly supports pre-approval for RSPs and generally takes the position that ICANN should try to strike the appropriate balance between ensuring the necessary technical capability of RSPs and allowing for the entrance of new RSPs to bring competition and innovation to the space. Additionally, XYZ believes that existing RSPs without a history of significant technical problems should be grandfathered in to avoid redundant and unnecessary technical evaluations for the RSPs or the registries that use them. *--Overarching Issue 2.5.1 - Application Fees--* XYZ strongly believes that it against the mission and purpose of ICANN for ICANN to charge anything more than its anticipated total cost to administer the application process for the new rounds. Importantly, ICANN must take into consideration the future revenue that ICANN will take in from auctions and increased registration volumes when setting initial application pricing. To do otherwise, would be a deliberate misinterpretation of *Implementation Guideline B* designed to overcharge applications and unjustly enrich ICANN. If ICANN takes in more from application fees and auction income than it spent in administering the application process, all such money should be fairly returned to applications. Any other use of the money would be against ICANN’s mandate and unfair to applicants. *--Overarching Issue 2.5.4 – Applicant Support--* XYZ believes that if an applicant is unable to afford any reasonable application fees, then he applicant is likely to be unable to be able to afford to operate a TLD. Accordingly, XYZ recommends against the financial assistance component of the ASP. *--Overarching Issue 2.7.3 – Closed Generics--* XYZ is strongly against closed generics, which only help to create unfair monopolies on generic terms that will benefit only existing large industry players at the expense of all others. This is very much against the mission of bringing competition and choice to the space. Also, Closed Generics go against internationally recognized trademark principles which do not allow exclusive rights in generic names without acquired distinctiveness. ICANN should formalize GNSO policy, making it consistent with the existing base Registry Agreement that Closed Generics should not be allowed. *--Overarching Issue 2.7.8 – Name Collisions--* It’s widely known that in the previous round, Name Collisions were shamelessly used by certain industry powers as an irrational fear-mongering manipulation tactic to create uncertainty and doubt about the new gTLD program. ICANN should not fall for this trap again and should not rely on any technical resources, data, research or other information that come from or is funded by parties with vested financial interests in the topic. *--Overarching Issue 2.10.1 – Base Registry Agreement--* There must be a base RA in place at the beginning of the application process. Any of the hundreds of provisions in the RA could heavily impact the economic decisions made by applicants and they need certainty up front before investing millions of dollars. Given that the existing RA can be used as a starting point, the work involved should be relatively minimal. -- *Grant Carpenter* General Counsel, XYZ ------------------------------ Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you.

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[Comments-gtld-subsequent-procedures-initial-03jul18] ICANN Org Input on the Subsequent Procedures PDP Initial Report
by Nanig Mehranian Sept. 26, 2018

Sept. 26, 2018

Dear All, Kindly find attached the ICANN Org Input on the Subsequent Procedures PDP Initial Report. Kind Regards, Nanig Mehranian Program Manager New gTLD Subsequent Procedures Strategic Programs GDD | Global Domains Division nanig.mehranian(a)icann.org<mailto:nanig.mehranian@icann.org> | (310) 578-8642 ICANN | Internet Corporation for Assigned Names & Numbers 12025 Waterfront Drive, Suite 300 | Los Angeles, CA 90094

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[Comments-gtld-subsequent-procedures-initial-03jul18] Business Constituency (BC) response to new gTLD Subsequent Procedures PDP initial report
by Steve DelBianco Sept. 26, 2018

Sept. 26, 2018

Attached is the response of ICANN’s Business Constituency (BC) on the Initial report from the PDP on procedures for subsequent rounds of new gTLDs (“Subsequent Procedures”). We have provided specific responses and follow-up questions alongside selected recommendations and questions from the PDP working group. Please also see our May-2017 comment to this working group’s prior questions: BC Response to New gTLD Subsequent Procedures PDP Questionnaire<https://www.bizconst.org/assets/docs/positions-statements/2017/2017_05May_2…>. -- This comment was drafted by Vivek Goyal, Andrew Mack, Susan Kawaguchi, and Marilyn Cade. It was edited by Steve DelBianco. It was approved in accord with our Charter. -- Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency

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[Comments-gtld-subsequent-procedures-initial-03jul18] Council of Europe remarks
by PEK Malgorzata Sept. 26, 2018

Sept. 26, 2018

Dear Sirs, Please find attached the Council of Europe`s remarks concerning the Initial Report on the new gTLD Subsequent Procedures Policy Development Process. Kind regards, Małgorzata Pęk Programme Officer - Media and Internet Division Council of Europe - Directorate General of Human Rights and Rule of Law phone: +33 (0)3 90 21 62 26

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[Comments-gtld-subsequent-procedures-initial-03jul18] Public Comment - Initial Report on the New gTLD Subsequent Procedures PDP (Overarching Issues & Work Tracks 1-4)
by Martin Sutton Sept. 26, 2018

Sept. 26, 2018

Please find attached the comments from the Brand Registry Group. Kind regards, Martin Sutton Brand Registry Group martin(a)brandregistrygroup.org<mailto:martin@brandregistrygroup.org> www.brandregistrygroup.org<http://www.brandregistrygroup.org> The contents of this email message and any attachments are intended solely for the addressee(s) and may contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the intended recipient of this message or their agent, or if this message has been addressed to you in error, please immediately alert the sender by reply email and then delete this message and any attachments. If you are not the intended recipient, you are hereby notified that any use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.

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[Comments-gtld-subsequent-procedures-initial-03jul18] Overarching Issues y Work Tracks 1-4
by Jenifer Lopez Sept. 26, 2018

Sept. 26, 2018

Estimados, NIC-Panamá considera que las preguntas técnicas solicitadas por el Grupo de trabajo de la GNSO deben ser abordadas y respondidas por el SSAC, cadenas de dos caracteres, que constan de una letra y un dígito, o dos dígitos, inequívocamente no deberían permitirse en futuras rondas de aplicaciones de gTLD debido al conflicto con la política de asignación de ccTLD y los códigos ISO de dos caracteres (que son externos a la ICANN), así como los problemas homográficos discutidos anteriormente. Saludos Cordiales, Lcda. Jenifer López de Gómez Administradora NIC-Panamá Dirección General de Tecnología de la Información y Comunicaciones - DITIC Universidad Tecnológica de Panamá - UTP +507 560-3400 / 3401 ***************Este mensaje (y sus adjuntos), en adelante "mensaje", ha sido enviado exclusivamente a su(s) destinatario(s) y es confidencial. Si usted recibe este mensaje por error, por favor bórrelo y comunique inmediatamente al remitente. Toda utilización o publicación, total o parcial, queda prohibida salvo autorización expresa. La UTP no podrá ser considerada responsable si el mensaje ha sido modificado y/o utilizado sin autorización. This message (and any attachments), are confidential intended solely for the people whose addresses appear. If you have received this message by error, please delete it and immediately notify the sender. Any use, dissemination or disclosure, either whole or partial, without formal approval is prohibited. The UTP will not therefore be liable for the message if modified and/or used without approval.**************

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments From ccTLD.PR
by Oscar Moreno De Ayala Diaz Sept. 26, 2018

Sept. 26, 2018

ccTLD.pr wholeheartedly supports and echos LACTLD's responses to the GNSO questions as per the communique attached to this message. ccTLD.pr considers that the technical questions requested by the GNSO Working Group should be addressed and answered by the SSAC, two-character strings, which consist of a letter and a digit, or two digits, unequivocally should not be allowed in future rounds of gTLD applications due to the conflict with the ccTLD assignment policy along with potentially new two-character ISO codes in the future, which are external to ICANN. Respectfully, Oscar Moreno de Ayala Díaz ccTLD .PR Manager

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