Hello, as per the invitation to comment on the subsequent procedures we submit our input and suggestions. Please do get in touch if any of our points have not been expressed clearly and/or need further explanation. 1.1.1 We would suggest approved RSPs have their own version of "EBERO" in their pre-validation process/accreditation and remove that as part of the Registry Agreement altogether if a "known"/prevalidated registry service provider is used, thus removing another redundancy double-checking per-application, if not removing the COI, EBERO, Data Escrow entirely as per answer 2.3.1. The reason to single out EBERO under the RSP model is they are generally acting as RSP for multiple registry operators and if the technical registry backend were to fail there is no call for having multiple separate agreements with each registry operator as that would only make things more difficult. 1.4.1 We suggest a TLD-type approach is considered, where an open-generic, closed-generic, brand, community are all priced at their reasonable fee. There are significant differences in the evaluation of these different types of TLDs and therefore the costs incurred by ICANN are also significantly different. 1.4.2 Considering a TLD-type model as suggested, and based on our own experience with a brand TLD, there was far too much overhead with the application that did not apply to a brand, all of which, if removed, would reduce the cost of a brand application substantially. In the case of using a pre-approved RSP the checks and tests required are also removed therefore removing another resource cost from ICANN, further justifying the reduction of application fees. 1.5.1 Yes, the fee should depend on the expected workload to process that application. Community evaluations or contention set resolutions require more resource from ICANN than a non-contested dot brand application. If our other suggestions in 2.3.1, 1.1.1, 4.3.2.4 are also considered, then a dot brand application would amount to a small fraction of work required to validate a comparable generic application. Applying the RSP model and removing the need for PDT and technical evaluation further justifies reducing the fee. We suggest using a continuously open application system, where the cost is defined per-application-type and a separate fee payable on top if the TLD becomes contested during the application hold term. This will allow lowering fees for uncontested strings and cover the costs of contention resolution in cases where a contention is, but avoid over-charging and making a surplus from applications where it is not justified. For example; a TLD is applied for by party 1, this TLD is then placed on hold for 3/6 months. If during this term another application is received from party 2 the TLD becomes contested, requiring all involved parties to pay an additional fee to resolve the contention set or allow any parties to cancel their application. Conversely, where no contention is found the TLD can simply proceed through the normal delegation process. 1.5.2 We see no negative implications to differentiating application types. Throughout the previous round they were informally categorized or defined on-the-fly during the application process. Formalizing this categorization would provide the much needed clarity that plagued the previous round. Additionally, beneficial effects would be gained, namely reduced evaluation complexity, costs and time. 1.6 We suggest a continuously available application system, eliminating the need for rounds entirely. A way to avoid potentially malicious attempts is to publish the applied-for TLDs immediately at their application and keep them on hold for 3 (or so) months (length as per 'rounds' windows suggestions) during which time a rival applicant may apply. 1.7.1 During a continuously available application system brands and communities should still be prioritized if applied for within the application window as of the first received application for that TLD. 2.3.1 Brand TLDs should be exempt from the requirements for an EBERO, COI or Data Escrow. As soon as the brand TLD is unable to meet its commitments it is only harming a single registrant and therefore itself. The true purpose of all these measures is to protect an end-user of a domain in the case of the registry business failing to operate. When the only end-user is the RO as well, these measures do not protect anyone. 4.3.2.4 We agree with the assertion, since the business model of a brand registry is not at-all for-profit, there is no reason why a model needs to exist. A brand applicant should only need to demonstrate that it is able to meet its financial commitments to ICANN. Additional questions: 2. As stated before, we would suggest a continuously open application period (at least for brand TLDs if not across the board) where a TLD can be applied for at any time, and is then placed on-hold to see if a rival application is submitted within 3 (6 or so, as per community consensus) months. This would allow time for rival applications to be put forward if necessary and remove the need to wait for 8 years before a TLD can be applied for. Best Regards, David Krizanic Chief Technology Officer Demys Limited, 33 Melville Street, Edinburgh, EH3 7JF Telephone: +44 (0) 131 226 0660 Demys Limited is a company registered in Scotland under number SC197176 ------------------------------------- Follow us on twitter @DemysLtd www.demys.com -------------------------------------