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