Dear Christa,

 

I am not sure if you intended for your email to be considered a Can’t Live With comment, but if so, please utilize the attached Issue Sheet. However, your email seems to go beyond the scope of a Can’t Live With comment, so perhaps it might be more appropriate as a public comment to the draft Final Report and/or even a subject of substantive discussions while the report is out for public comment (to be decided by the Co-Chairs and WG of course).

 

Best,

Steve

 

From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces@icann.org> on behalf of "christa@dottba.com" <christa@dottba.com>
Date: Wednesday, July 15, 2020 at 9:12 AM
To: "gnso-newgtld-wg@icann.org" <gnso-newgtld-wg@icann.org>
Cc: Christa Taylor <christa@mmx.co>
Subject: [Gnso-newgtld-wg] Applicant Support - Bid Credits, Multiplier concerns

 

Hello,

 

Another attempt at raising the flag on the changes to Applicant Support.

 

Bid Credit, multiplier or other mechanism could create an increase in the volume of AS applications from applicants who otherwise would not have considered AS because of new larger financial incentives.  Concerns and comments  that need to be addressed:

 

  1. How AS Applicants are provided with sufficient time to gain sufficient auction knowledge, impact on business plans, raise funding, etc.
  2. Do not consider financial benefits of the AS applicants entering into a JV with a third-party creating a potential opportunity for gaming – see my email from last week. 
  3. Implications on maximum values – low/mid/high all impact strategy and raise additional questions and concerns i.e. significant maximum values increased the financial benefits and potential for abuse  
  4. Consideration on the repayment of auction funds?  What if they are wildly successful and recover all funds in say the first year?  Consideration to future AS might be nice…
  5. Repayment of auction ‘funds’ – Rationale 9 should state that repayment includes auction credits i.e. “shall require the applicant to repay the full amount of financial support received including auction bid credit, multiplier or other mechanism through the ASP Program plus an additional ten percent (10%)”.
  6. Implications on other contention set applicants who are impacted by the AS applicants who are financially incentivized to only participate in the Auction of Last Resort.  The AS Applicant now holds the Trump card to use the Auction of Last Resort and thereby limiting everyone else in that contention set from the ability to use another auction method.  See item #2 re:  JV.  There should not be a race to the AS Applicant to enter into a JV to gain the auction multiplier – if the credit no longer apply to this, we need to state it but again, it then changes the dynamics on resolving the contention set.

 

In short, the multiplier has been added without the requisite consideration required to prevent the very concern everyone was trying to prevent in the 2012 round.  The bid credits, multiplier needs further deliberation to carefully balance the needs of all stakeholders while ensuring we’re not opening the doors to abuse and gaming. 

 

Cheers,

 

Christa

 

 

Christa Taylor

CMO | MMX.CO

M: +1 (604) 961-9460

Email: christa@mmx.co

 

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