Dear Sir / Madam, The public comment on New gTLD Subsequent Procedure PDP is appended below for your kind perusal and consideration please:Public Comments The Government of India submits the following comments on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1 – 4):- On Different TLD Types Developing explicit TLD categories should be seriously considered as it can help simplify the process for applicants by creating diverse categories that provide structure, hence allowing for a smoother application process. Additionally, different application processes or requirements can be developed for different categories, and instead of the current single fee model, a cost-based fee structure suitable to each TLD category can be developed so as to allow for better representation for local communities and developing countries. On Applicant Support The cost of a new gTLD extends beyond just the application fee to the cost of the application process as well as running a new gTLD. Most applicants in the 2012 round had no clear sense of the real costs involved in applying for or running a new gTLD which acted as a deterrent to many. Interested applicants should be provided with a general estimation of fees and cost that would be required by the whole procedure before filing of the gTLD application. The suggestion to include a “middle applicant” comprising of struggling regions that are further along in their development compared to underserved or underdeveloped regions is one that has great merit. It would provide developing economies with more opportunities in the DNS space while bearing in mind that their economic and developmental realities and priorities are different from both developed and underserved regions. A suggested approach in which the ASP can be extended to benefit the “middle applicants” is by reducing the application fee of $185,000 USD, but not to the extent of the reductions availed by the underserved regions, so as to encourage them to cross the threshold in the domain name space. Further, there can be special outreach programmes tailored towards “middle applicants” which would focus more on how the new gTLDs may practically benefit them as against the more awareness-centric outreach programmes for underdeveloped economies and underserved regions. The PDP’s suggestion of extending the ASP to areas other than financial support such as inclusion of mentorship on the management, operational and technical aspects of running a registry and employment of a multifaceted approach based on pre-application support is meaningful and efficient. It can be further extended to include aid in filing objections, support in post-delegation operations, and transfer of capacity building skills in various key areas required for running a registry. This will help make the ASP more comprehensive and result in applicants being provided assistance in every step of the application procedure. The ASP can also set up a support system to guide new applicants through the application procedure and deal with all the questions and queries of the applicants about navigating the application process as it can be a daunting task for a first-time applicant. The success of the ASP can be measured by its use i.e. out of the applicants that considered applying for a new gTLD, how many completed the application process. This metric will also take into account the extension of support for applicants beyond the financial aspect. On Applicant Guidebook The Applicant Guidebook, in its current form, is verbose and lacks clarity. Applicants not particularly familiar with ICANN have faced difficulties in navigating the application procedure partly due to the complicated nature of the Applicant Guidebook. It is a massive document that should be made more user-friendly and requires simplification so that a larger number of community members can access, comprehend and apply the information contained therein with greater ease. Therefore, India supports the initial report’s recommendations under section 2.4.1.c.2 that seek to enhance accessibility for ease of understanding especially for non-native English speakers and those that are less familiar with the ICANN environment, On Application Fees The Applicant Support Program (2012) provided a very limited number of qualifying applicants with the opportunity to pay a reduced evaluation fee of USD $47,000 instead of the full fee of USD $185,000. The application fee pegged at USD $185,000 is unreasonably high and must be revised to make it more affordable for applicants from developing as well as underdeveloped economies of the world. On Reserved Names The working group is considering a proposal to remove the reservation of 2-character strings at the top level consisting of one letter and one number. In reference to this proposal, India would like to reiterate its position that 2-character strings at the top level consisting of one letter and one number should remain reserved. The release of such strings can lead to visual confusion and conflict with existing ccTLDs as certain strings can look deceptively similar; for example .IN and .1N. Hence, India maintains that 2-character strings at the top level consisting of one letter and one digit should remain reserved. Further, India would like to reiterate that we have always objected to the release 2-Character Country Codes at the Second Level and have communicated our reservations to the ICANN Board in the past as such release can give rise to consumer confusion along with the possibility of misuse by mala fide registrants. On Objections (GAC Early Warning System) Comments The GAC early warning system is a useful mechanism for commencing a discussion between a concerned government and an applicant on particular public policy issues or concerns. It leads to constructive dialogue that can help applicants better understand the concerns of governments and help governments better understand how that applicant plans to operate the proposed gTLD. It also ensures that public policy or related concerns could be addressed prior to delegation of the gTLD. The GAC early warning system is an essential aspect of any upcoming gTLD rounds. On Internationalized Domain Names India is a country of great linguistic diversity and to encourage its non-English speaking population to connect to the internet, places a great amount of significance on IDNs. As a result, India’s ccTLD is available in 15 Indian languages. India would like to propose that ICANN lower the application fee for a string in multiple IDN scripts, particularly where simultaneous IDNs are required in countries of great linguistic diversity.Regards,Systems Analyst - .IN Registry (NIXI)Tel. +91 11 48202000/2011 ------------------------------------------------------------------------------------------------------------------------------- [NIXI is on Social-Media too. Kindly follow us at: Facebook: https://www.facebook.com/nixiindia & Twitter: @inregistry ] This e-mail is for the sole use of the intended recipient(s) and may contain confidential and privileged information. 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