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

[Comments-gtld-subsequent-procedures-initial-03jul18] Comment on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process
by Stephen Deerhake ＠ ASNIC Sept. 26, 2018

Sept. 26, 2018

AS Domain Registry (.as) welcomes the opportunity to comment on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process. The Registry strenuously objects to the idea that 2 character (1 alpha, 1 numeric), as envisioned by Question 2.7.1.e.2, should EVER be introduced as gTLD strings. The reasons for this are detailed in the statements submitted by APTLD, CENTR, and LACNIC, which AS Domain Registry fully support. AS Domain Registry (.as) GDNS, LLC Stephen Deerhake General Manager and Director of Registry Services

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on Initial Report on the New gTLD Subsequent Procedures Policy Development
by Alexander Schubert Sept. 26, 2018

Sept. 26, 2018

All comments made by Alexander Schubert, Riga, Latvia in his personal capacity. Co-founder of .berlin and active participant in several work tracks. * In 2.5.1.c.2: I assume "principal" should be "principle"? * In 2.5.1.e.4: Are there policy, economic, or other principles or factors that might help guide the establishment of the floor amount? As we will most likely see several more rounds before we switch to continues application mode and as by the start of the next round about 8 to 9 years since the 1st round have gone by there will be a very high demand in applications. In order to keep that amount manageable and in order to prevent an application stack that would take 2,3 or maybe even 3 years to work off it would be only natural to keep the application fees for the coming round HIGH. The results would be: * A manageable application stack (ideally to be processed within a year, so the next round could start a year later) * Less speculative registrations (less warehousing) * Speedy processing for all applicants (no risk, that an application might be at the end of a long stack) The application fee floor could be slowly lowered round by round - adapting to the amount of applications of the previous round I suggest an application fee of 500,000 USD in the next round: If that should yield to only 100 or less applications; no problem as the following round would come up within a few month then (short application stack, speedy processing) Sadly in our current world seemingly a financial barrier is the only real working barrier. And absent a high entry barrier we will be FLOODED with new gTLDs - which eventually renders the DNS senseless * 2.6.1: Application Queuing (WT2) - general remark (if has to be tied with a question then 2.6.1.e.3): o The entire "application queuing" came only up as way more application were submitted than expected. THIS time we do KNOW that we have to queue! So why not simply including that task into the application process? * Any entity that doesn't wish speedy processing would indicate already at submission of the application. * Every application will receive a random (many digit long) "queueing number" assigned by the application system (yes: computers can create RANDOM numbers, since decades already) * The applications are then queued by these numbers * Absolutely no need to start hilariously complicated processes like "auctions" * 2.6.1.e.4: o CAUTION with statements like "those from the Global South should be prioritized". In other words if portfolio applicants use "global south" tax havens (like Seychelles) instead of the Caribbean: they get prioritized? We live in a globalized world: the applicant entities can be positioned ANYWHERE on the globe! * 2.6.1.c.4: o Absolutely RIDICIOUS thought. Why granting portfolio applicants EXTRA PERKS? Doesn't make ANY sense at all. Who comes up with such heinous thoughts? Why would we create BENEFITS for portfolio applicants? I thought the goal was to PREVENT "warehousing"? So NO: There is no cherry picking in the queueing process within several applications from one applicant. Thanks, Alexander Schubert

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] MarkMonitor Comments on Subsequent Procedures Working Group Initial Report
by King, Brian Sept. 26, 2018

Sept. 26, 2018

Hello, Please find MarkMonitor's comments attached, and please let me know if you have any questions. Best regards, Brian Brian J. King Director of Internet Policy & Industry Affairs MarkMonitor / Part of Clarivate Analytics Phone: +1 (443) 761-3726 brian.king(a)markmonitor.com<mailto:brian.king@markmonitor.com>

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Google Registry - Comment on Subsequent Procedures Initial Report
by Stephanie Duchesneau Sept. 26, 2018

Sept. 26, 2018

To Whom It May Concern, Please find attached the comments by Google Registry on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process. Best, Stephanie -- Stephanie Duchesneau | Domains Policy and Compliance | sd(a)google.com | 202-642-2325

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] NIC Mexico | .MX - Comments on gTLD Subsecuent procedures
by José Ernesto Grimaldo Tijerina Sept. 26, 2018

Sept. 26, 2018

A quien corresponda, NIC México<http://www.nicmexico.mx/> es la organización encargada de la administración del nombre de dominio territorial (ccTLD<http://www.nicmexico.mx/es/NicMx.Historia>, country code Top Level Domain) .MX, el código de dos letras asignado a cada país según el ISO 3166<http://www.nicmexico.mx/jsf/static_content/external_redirect.jsf?url=http:/…>. Entre sus funciones están el proveer los servicios de información y registro para .MX así como la asignación de direcciones de IP y el mantenimiento de las bases de datos respectivas a cada recurso. A continuación, presentamos la posición de NIC Mexico y .MX respecto al "Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group" En referencia a las preguntas del Reporte Inicial: "2.7.1.e.2: If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit (or digits more generally), should the reservation of those strings be removed? Why or why not? Do you believe that any additional analysis is needed to ensure that these types of strings will not pose harm or risk to security and stability? Please explain." NIC Mexico | .MX establece que: Las preguntas técnicas solicitadas por el Grupo de trabajo de la GNSO deben ser abordadas y respondidas por grupos técnicos relevantes como el SSAC. Que 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. Atentamente. NIC Mexico | .MX Ernesto Grimaldo | Registry .MX English ***** NIC México is the organization in charge of the administration of the territorial domain name (ccTLD, country code Top Level Domian) .MX, the two letters code assigned to each country following the ISO 3166. Among its functions are the provisioning of information and registration services for .MX as well as the IP addresses assignation and the respective maintenances of the data bases associated to each resource. Following, is .MX - NIC Mexico´s input with respect to the Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group, which is chartered to evaluate what changes or additions need to be made to existing new gTLD policy recommendations and includes materials from the full Working Group and four sub-teams within the Working Group, Work Tracks 1-4. In reference to the Initial Report following questions: "2.7.1.e.2: If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit (or digits more generally), should the reservation of those strings be removed? Why or why not? Do you believe that any additional analysis is needed to ensure that these types of strings will not pose harm or risk to security and stability? Please explain." NIC Mexico | .MX states that: The technical questions asked by the GNSO Working Group need to be addressed and answered by relevant technical bodies like the SSAC. That 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. Sincerely yours. NIC Mexico | .MX Ernesto Grimaldo | Registry .MX Este mensaje contiene información confidencial y se entiende dirigido y para uso exclusivo del destinatario. Si recibes este mensaje y no eres el destinatario por favor elimínalo, ya que difundir, revelar, copiar o tomar cualquier acción basada en el contenido está estrictamente prohibido. Network Information Center, S.A. de C.V., ubicado en Ave. Eugenio Garza Sada 427 L4-6 Col. Altavista, Monterrey, México, C.P. 64840 recaba tus datos personales necesarios para: la prestación, estudio, análisis y mejora del servicio, la realización de comunicaciones y notificaciones; la transferencia y publicación en los casos aplicables; el cumplimiento de la relación existente; así como para la prevención o denuncia en la comisión de ilícitos. Si eres colaborador o candidato a colaborador de NIC México, tus datos serán utilizados para: la creación y administración de tu perfil como profesionista; el otorgamiento de herramientas de trabajo; la realización de estudios; el otorgamiento de programas y beneficios para mejorar tu desarrollo profesional; la gestión y administración de servicios de pago y/o nómina; así como para contacto y/o notificaciones. Si participas en promociones o en estudios podrás dejar de participar. Para mayor información revisa el Aviso de Privacidad<http://www.nic.mx/es/NicMx.AvisosDePrivacidad>. This message contains confidential information and is intended only for the individual named. If you are not the named addressee please delete it, since the dissemination, distribuition, copy or taking any action in reliance on the contents is strictly prohibited. Network Information Center, S.A. de C.V., located on Av. Eugenio Garza Sada 427 L4-6, Col. Altavista, Monterrey, Mexico, CP 64840 collects your personal data which is necessary to: provide, research, analyze and improve the service; send communications and notices; transfer and publish your personal data when applicable; fulfill the existing relationship; prevent or inform in the commission of unlawful acts or events. If the data is processed in your quality of candidate or collaborator of NIC Mexico, the purpose of treatment is to: create and manage your profile as a professional; provide you with working tools; conduct studies; grant benefits and programs to enhance your professional development; manage and administrate payment services and/or payroll; as well as to contact you. If you participate in promotions or surveys you may stop or quit your participation at any time. For more information read the Privacy Note<http://www.nic.mx/es/NicMx.AvisosDePrivacidad>.

2 1

[Comments-gtld-subsequent-procedures-initial-03jul18] Sending on behalf of Valideus: Valideus comments on Sub Pro Initial Report
by Steve Chan Sept. 26, 2018

Sept. 26, 2018

Note: sending Valideus’ public comments on their behalf due to challenges with the submission page. Steven Chan  Policy Director, GNSO Support ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094-2536  Mobile: +1.310.339.4410 Office Telephone: +1.310.301.5800 Office Fax: +1.310.823.8649 Find out more about the GNSO by taking our interactive courses and visiting the GNSO Newcomer pages. Follow @GNSO on Twitter: https://twitter.com/ICANN_GNSO Follow the GNSO on Facebook: https://www.facebook.com/icanngnso/ http://gnso.icann.org/en/

1 0

[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.

1 0

[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.

1 0

[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

1 0

[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

1 0