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

[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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[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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