CIRA is pleased to submit the attached comments with respect to ICANNs invitation to comment on the New gTLD Subsequent Procedures. Our comments focus on a number of specific areas: - Encouraging the creation of a registry certification program operated and funded independently of the gTLD application process - Recommending a reduction in the application fee considering the reduced evaluation requirements an RSP program would provide, the limited need for a legal set-aside and a clear surplus from the first round. We believe a reduced fee would lower the barrier to entry and allow geo-based applicants (who are typically publicly funded) to pursue their own platform - A further recommendation to create a tiered pricing model for variable fees particularly as related to minimum charges. Small brands and geo-based Registry Operators see the current annual minimum of $25KUSD as a real barrier to entry. - We also would hope that ICANN would pursue the next "round" (or acceptance of applications) sooner rather than later especially as applied to brand and geo-applicants. Regards Richard Schreier Product Manager Canadian Internet Registration Authority (CIRA) Tel: (613) 237-5335 x222 | www.cira.ca<http://www.cira.ca/> [Description: Aon_Email logo EN]
