Apologies, I was unable to get to this sooner.
Bid credits could be gamed by:
- An ASP applicant receives bid credits, multipliers and other features and enters into a joint venture with a non-AS applicant. In turn, the non-ASP applicant receives the financial benefits that otherwise would not have been available to them.
- An ASP applicant receives the benefits of the bid credits, multipliers, other and subsequently ‘goes out of business’ and transfers ownership to a friendly party. The third party receives the benefits of the bid credits. As noted, we should clearly define ‘going out of business’ and ideally, provide an overview on how the transfer process is to be administered to avoid any loopholes on transfers to friendly party’s.
- If we haven’t already updated the repayment of bid credits, this would allow a change of control to occur and the ‘applicant to replay the full amount of the financial support received through the ASP program plus an additional ten percent’ without having to repay the value of the bid credits. We need to have include both - the application fee and the value of the bid credits, multipliers, other.
The value of the auction bid credit, multipliers, other will need to be substantial if it is to be meaningful to the AS applicants. My concern is that we don’t know the maximum value of the bid credits, multiplier, etc. and haven’t defined any type of payback schedule so the value of the benefits could be large which increases the motivation for gaming.
Cheers,
Christa
From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces@icann.org> On Behalf Of Jeff Neuman
Sent: December 1, 2020 6:12 AM
To: gnso-newgtld-wg@icann.org
Subject: [Gnso-newgtld-wg] Outstanding Final Questions on Applicant Support
All,
This is the Second topical E-mail on outstanding questions being “put to the list.” The first was on Predictability. This one covers Applicant Support (Topic 17).
Remember: We are down to the wire on this, so unless you have a VERY strong objection to these, we will put these into the document. If you do have a big issue with the responses to these (all of which were previously discussed and in emails over the past 1.5 months), please let us know ASAP. Only comments that provide the rationale for the objection with proposed replacement text to address the specific outstanding questions will now be considered.
Lets not let the perfect be the enemy of the good.
- Define the “Middle Applicant”?
- The GAC highlights the importance of the implementation work as noted in the final report, regarding defining the “middle applicant” and drawing on expertise to develop appropriate program outreach, education and application evaluation.
- Our recommendation states: Outreach efforts should not only target the Global South, but also “middle applicants,” which are located in struggling regions that are further along in their development compared to underserved or underdeveloped regions. In addition, the evaluation criteria for Applicant Support must treat “middle applicants” similar to those currently set forth in Criteria #1, Section 4 (Operation in a developing economy) of the Financial Assistance Handbook.
- Recommendation: Rather than providing a definition of “middle applicants”, we can remove the term from the recommendation to state: “Outreach efforts should not only target the Global South, but also those located in struggling regions that are further along in their development compared to underserved or underdeveloped regions. In addition, the evaluation criteria for Applicant Support must treat those applicants similar to those currently set forth in Criteria #1, Section 4 (Operation in a developing economy) of the Financial Assistance Handbook.
- Gaming Bid Credits. The RySG stated that they have “Significant concerns on how bid credits, multipliers, and other features may be used in other unintended ways beyond benefiting AS applicants, and how the risk of gaming can be mitigated.’
- On the Applicant Support call we asked the Registries to provide more information on their concerns on how the credits could be gamed. No examples have been provided.
- Action Item: Please provide examples of the types of gaming that you are concerned about and any recommendations to handle those examples. Note: If we do not get any examples, then our recommendations will stay as is.
Please have your comments (If any) by no later than 23:59:59 UTC on Thursday, December 3, 2020.
Sincerely,
Jeff & Cheryl
Co-Chairs, SubPro PDP
| Jeffrey J. Neuman Founder & CEO JJN Solutions, LLC p: +1.202.549.5079 |
