RE: Public Comment on Initial Report of the Cross-Community Working Group on New gTLDAuction Proceeds (CCWG-AP) <https://www.icann.org/public-comments/new-gtld-auction-proceeds-initial-2018...> 1. I find ICANN's whole scheme of auctioning off new gTLDs to the "highest bidder" repugnant and a violation of the principles set out by Jon Postel in RFC 1591 and the advice given to ICANN by the U.S. Department of Justice Antitrust Division in December, 2008 (attached to a letter to ICANN from NTIA <https://www.ntia.doc.gov/files/ntia/publications/icann_081218.pdf>): "... These designated authorities are trustees for the delegated

[top-level] domain, and have a duty to serve the community. The designated manager is the trustee of the top-level domain for ... the global Internet community. Concerns about "rights" and "ownership" of domains are inappropriate. It is appropriate to be concerned about "responsibilities" and "service" to the community .... Significantly interested parties in the domain should agree that the designated manager is the appropriate party ... it is also appropriate for interested parties to have some voice in selecting the designated manager ..."--Jon Postel, March, 1994, RFC 1591 <https://www.ietf.org/rfc/rfc1591.txt>.

"... The [U.S. Department of Justice Antitrust] Division makes two specific recommendations. First ICANN’s general approach to new gTLDs should be revised to give greater consideration to consumer [registrant] interests … Second, the RFP process and proposed registry agreement should include provisions that would enable ICANN to constrain new registry operators from exercising market power. In particular, ICANN should establish competitive mechanisms for authorizing new gTLDs and renewals of gTLD registry agreements whereby prospective gTLD operators would compete for gTLDs by proposing registry terms – including maximum fee schedules – that would provide consumer [registrant] benefits."--U.S. Department of Justice Antitrust Division, Dec 3, 2008 <https://drive.google.com/file/d/0B3zjyRMTBSc7UzViS0stOWhQR3c/view?usp=sharin...>

2. Auctions (both "private" and "ICANN last resort") have corrupted ICANN and the processes for developing new gTLDs--*"it's all about the money"*--and increase costs that new gTLD registry operators can only recoup by charging registrants far more money for new gTLD domain name registrations and renewals than necessary had ICANN followed RFC1591 and the advice of the U.S. Department of Justice Antitrust Division cited above. In effect, consumers (domain name registrants) are bearing, directly and indirectly, the entire costs of *ICANN's ill-conceived, horribly implemented <https://www.domainmondo.com/2014/09/icann-insiders-on-new-gtlds-mistakes.html>,* and* corrupt program for new gTLDs*. 3. Adding insult to injury,* ICANN* and its "contracted parties" have engaged in "*consumer* (registrant) *fraud*" by failing to warn registrants worldwide of *new gTLDs* "failing to work as expected on the internet" <http://www.circleid.com/posts/20140207_more_problems_crop_up_universal_accep...> of which ICANN and its Security and Stability Advisory Committee (SSAC) have been well aware since 2003. Further, ICANN has failed to inform and warn domain name registrants worldwide that *unlike the market dominant legacy gTLD .COM*, which has price controls, *new gTLDs, by design*, come with no price controls and any of ICANN's monopoly new gTLD registry operators can (and have <https://onlinedomain.com/2017/03/08/domain-name-news/frank-schilling-just-ki...>) increase pricing of registration and renewal fees (by 3000% or more), from year to year. 4. I have read with interest other comments submitted by certain "contracted parties" advocating ICANN allocate the auction proceeds for a worldwide marketing campaign a/k/a "awareness campaign" for the benefit of "contracted parties" who have discovered that many consumers (registrants) don't want their "garbage extensions" that "fail to work as expected on the internet," "break stuff," and are totally untrustworthy as they have no maximum price increase caps or schedules. Should ICANN succumb to this "money grab" by "contracted parties," I will enjoy petitioning, along with others, the U.S. government's Internal Revenue Service (IRS), the California State Attorney General, and other governmental authorities, for revocation of ICANN's nonprofit, IRC 501(c)(3) status, and the imposition of other statutory penalties and remedies. 5. In lieu of the contracted parties' proposed "money grab" above and all other third parties' already proposed, or yet to come, "money grabs," ICANN should instead end this entire repulsive and tawdry "money grab" stampede, and announce it will set aside ALL of the auction proceeds for the benefit domain name registrants who have, indirectly, provided these funds, by: a) ICANN conducting continuous worldwide "awareness campaigns" to warn all domain name registrants, all prospective registrants, and all other consumers, about the *new gTLDs* "failing to work as expected on the internet <http://www.circleid.com/posts/20140207_more_problems_crop_up_universal_accep...>" and the* lack of consumer protection in new gTLDs *against price gouging, exorbitant price increases, and total lack of price caps and controls, unlike the market dominant gTLD .COM domain names; b) setting up a restitution fund for consumers (registrants) worldwide who have claims as a result of the aforementioned "consumer fraud;" c) funding research, and continuously publishing the results via notices on the "home" and "landing" pages of all ICANN-accredited registrars, ICANN.org, and newgTLDs.icann.org,, ranking all new gTLDs by "usability,"* i.e.,*testing all new gTLDs in comparison against gTLD .COM, to determine the extent to which each new gTLD "fails to work as expected on the internet <http://www.circleid.com/posts/20140207_more_problems_crop_up_universal_accep...>", along with wholesale pricing information and other pricing disclosures already mentioned, so that ALL consumers (registrants) can make "informed decisions" in deciding whether, or which, gTLD to select, in registering a domain name; d) funding ALL of the continuous data collection and surveys recommended in the Competition, Consumer Trust, and Consumer Choice Review Team (CCT) Final Report & Recommendations <https://www.icann.org/public-comments/cct-final-recs-2018-10-08-en>, and other continuous data collection and surveys as may be appropriate. 6. Disclosure: I have neither monetary claims nor pecuniary interests (individually or otherwise) related to providing any of the services suggested above. Respectfully submitted, John Poole, gTLD domain name registrant and *Editor, *DomainMondo.com <https://www.domainmondo.com/2018/12/news-review-verisign-vrsn-new-gtld-web.h...> cc: ICANN Chairman Cherine Chalaby, ICANN CEO Goran Marby, ICANN GDD Cyrus Namazi, NTIA (David Redl), FTC, US Department of Justice Antitrust Division