Dear all, thanks for all the valuable feedback you provided. It seems like there is no consensus on the proposal to give priority to IDNs and geoTLDs. The main reason for that is that categorization cannot lead to equitable treatment, in this case e.g. because there are IDNs that are dotBrands. It was also felt that the other mechanisms described in the proposal provide for sufficient metering. I therefore suggest that those still wishing to ask for priority for certain groups do so in their individual comments. Please find below an updated version of the comment. I have put the amendments in square brackets to make it easier for you to identify the changes. I plan to submit this comments shortly before the deadline. Please feel free to send additional comments, which I will try to incorporate. Thanks, Thomas The below comments are made on behalf of eco, the Association of the German Internet Industry (www.eco.de). eco is the German Internet Industry Association with about 600 members from different Internet industry sectors. The association represents over 200 ISPs and Registrars as well as Registries. First of all, ICANN should take all reasonable steps to increase the speed of evaluating all applications. There are synergies arising from the limited number of Registry Service Providers, which lead to partially congruent responses to the technical questions. Applicants that have applied for multiple strings may have used partially congruent information in business plans etc. Hence, the evaluation process can be streamlined without any loss of quality by identifying the variations and determining their impact on the overall assessment. Where possible, applications should be assigned to evaluators in a manner that allows for the common evaluation of substantially similar applications. We also believe that there will be a natural sequencing after the publication [of] the results of the initial evaluation for all applications due to objections, withdrawals, GAC Advice and contentions, but also due to factors beyond ICANN's control since applicants need to return signed contracts and also apply for the delegation, which provides for additional sequencing. Additionally, all applicants should be given the opportunity to opt for their TLD being delegated at a later stage. [ICANN should consider to offer financial incentives for those who opt out.] Secondly, the ICANN Community has been advised that the effects of delegating new TLDs into the root zone will be monitored and analyzed. ICANN should seek more information on how this process is envisaged by the technical experts. How many TLDs will they allow to be delegated at first? Will there be a pause for analysis afterwards? How long might such pause be? What will be the sequence of delegations afterwards? ICANN should synchronize its metering with the plans of the technical experts, if possible. [sentence on IDNs and geos removed] Should additional metering be needed, the sequence should be as follows: All applicants [wording on IDNs and geos removed] will be sent the contracts for execution at the same time, unless their application requires an extended evaluation. Natural sequencing in contract negotiation and execution as well as applying for delegation will provide for natural sequencing. Afterwards, non objected TLDs will be handled in the same manner, unless there is GAC Advice, extended evaluation or a contention. After that, those who opted out will be handled in the same manner, unless there is GAC Advice, extended evaluation or a contention. For cases where there is GAC Advice, an extended evaluation or a contention, the handling will occur as the cases are resolved. ___________________________________________________________ Thomas Rickert, Attorney at Law Director Names & Numbers ------------------------------------- eco - Verband der deutschen Internetwirtschaft e.V. Lichtstraße 43h 50825 Köln Fon: +49 (0) 221 - 70 00 48 - 0 Fax: +49 (0) 221 - 70 00 48 - 111 E-Mail: thomas.rickert@eco.de Web: http://www.eco.de --------------------------------------------------- eco - Verband der deutschen Internetwirtschaft e.V. Geschäftsführer: Harald A. Summa Vorstand: Prof. Michael Rotert (Vorsitzender), Oliver Süme (stv. Vorsitzender), Klaus Landefeld, Thomas von Bülow, Felix Höger Vereinsregister: Amtsgericht Köln, VR 14478 Sitz des Vereins: Köln Am 14.08.2012 um 14:02 schrieb Thomas Rickert:
Dear all, thank you for the responses you sent to me. I have amalgamated them into the following statement. We have not yet answered the question how ICANN should sequence the handling even if we apply the mechanisms we propose.
Should ICANN send the contracts to all IDNs and geoTLDs at the same time? How should ICANN sequence within the piles of applications.
I have included a proposal on that at the end of the statement. Please provide your feedback by Friday 10 AM CEST.
Thanks and regards, Thomas
The below comments are made on behalf of eco, the Association of the German Internet Industry (www.eco.de). eco is the German Internet Industry Association with about 600 members from different Internet industry sectors. The association represents over 200 ISPs and Registrars as well as Registries.
First of all, ICANN should take all reasonable steps to increase the speed of evaluating all applications. There are synergies arising from the limited number of Registry Service Providers, which lead to partially congruent responses to the technical questions. Applicants that have applied for multiple strings may have used partially congruent information in business plans etc. Hence, the evaluation process can be streamlined without any loss of quality by identifying the variations and determining their impact on the overall assessment. Where possible, applications should be assigned to evaluators in a manner that allows for the common evaluation of substantially similar applications.
We also believe that there will be a natural sequencing after the publication the results of the initial evaluation for all applications due to objections, withdrawals, GAC Advice and contentions, but also due to factors beyond ICANN's control since applicants need to return signed contracts and also apply for the delegation, which provides for additional sequencing.
Additionally, all applicants should be given the opportunity to opt for their TLD being delegated at a later stage.
Secondly, the ICANN Community has been advised that the effects of delegating new TLDs into the root zone will be monitored and analyzed. ICANN should seek more information on how this process is envisaged by the technical experts. How many TLDs will they allow to be delegated at first? Will there be a pause for analysis afterwards? How long might such pause be? What will be the sequence of delegations afterwards? ICANN should synchronize its metering with the plans of the technical experts, if possible.
Should the opt-out not provide for sufficient results, IDNs and geoTLDs should go first. The reason for that is that namespaces in these TLDs serve the global public interest in particular. Should additional metering be needed, the sequence should be as follows:
All applicants for geoTLDs and IDNs will be sent the contracts for execution at the same time, unless their application requires an extended evaluation. Natural sequencing in contract negotiation and execution as well as applying for delegation will provide for natural sequencing.
Afterwards, non objected TLDs will be handled in the same manner, unless there is GAC Advice, extended evaluation or a contention.
After that, those who opted out will be handled in the same manner, unless there is GAC Advice, extended evaluation or a contention.
For cases where there is GAC Advice, an extended evaluation or a contention, the handling will occur as the cases are resolved.
Am 31.07.2012 um 20:20 schrieb Thomas Rickert:
Dear all, you will have heard that ICANN has recently published an announcement, due to which it seeks input on gTLD Batching, see
https://www.icann.org/en/news/announcements/announcement-29jul12-en.htm
eco is planning to submit a comment.
With this e-mail I would like to encourage all of you to provide me with input by August 5th.
I will amalgamate your input into one statement and send it to this list for your review.
Please let me know if you have any questions. Also, please let me know if you would like me to include other / additional contacts inside your company.
Best regards, Thomas Rickert
___________________________________________________________ Thomas Rickert, Attorney at Law Director Names & Numbers
------------------------------------- eco - Verband der deutschen Internetwirtschaft e.V.
Lichtstraße 43h 50825 Köln
Fon: +49 (0) 221 - 70 00 48 - 0 Fax: +49 (0) 221 - 70 00 48 - 111 E-Mail: thomas.rickert@eco.de Web: http://www.eco.de
---------------------------------------------------
eco - Verband der deutschen Internetwirtschaft e.V. Geschäftsführer: Harald A. Summa Vorstand: Prof. Michael Rotert (Vorsitzender), Oliver Süme (stv. Vorsitzender), Klaus Landefeld, Thomas von Bülow, Felix Höger Vereinsregister: Amtsgericht Köln, VR 14478 Sitz des Vereins: Köln
___________________________________________________________ Thomas Rickert, Rechtsanwalt Schollmeyer & Rickert Rechtsanwaltsgesellschaft m.b.H. (i.e. law firm) Geschäftsführer / CEO: Torsten Schollmeyer, Thomas Rickert HRB 9262, AG Bonn
Büro / Office Bonn: Kaiserplatz 7-9, 53113 Bonn, Germany Phone: +49 (0)228 74 898 - 0
Büro / Office Frankfurt a.M.: Savignystraße 43, 60325 Frankfurt, Germany Phone: +49 (0)69 714 021 - 56
Zentralfax: +49 (0)228 74 898 - 66
mailto: rickert@anwaelte.de skype-id: trickert web: www.anwaelte.de
___________________________________________________________ Thomas Rickert, Rechtsanwalt Schollmeyer & Rickert Rechtsanwaltsgesellschaft m.b.H. (i.e. law firm) Geschäftsführer / CEO: Torsten Schollmeyer, Thomas Rickert HRB 9262, AG Bonn Büro / Office Bonn: Kaiserplatz 7-9, 53113 Bonn, Germany Phone: +49 (0)228 74 898 - 0 Büro / Office Frankfurt a.M.: Savignystraße 43, 60325 Frankfurt, Germany Phone: +49 (0)69 714 021 - 56 Zentralfax: +49 (0)228 74 898 - 66 mailto: rickert@anwaelte.de skype-id: trickert web: www.anwaelte.de