Good evening: Thankyou, Christa. Fair points, but to recall my previous contributions…: 1. If an application is evaluated positively for Application Support, that must then be immune from challenge through contention and auctions. If evaluators confer AS status, then ipso facto, ICANN must work on ensuring that available - by definition - limited resources are NOT expended on unnecessary excursions into contention and auctions. 2. AS is a rather limited financial benefit. In practice AS beneficiaries will probably require other third party funding. In which case the idea that ICANN would set up an auction to attack an AS application - thus prejudicing the applicant's standing with its third party funding - is inconceivable. 3. Evaluators should also take into consideration whether an AS application also qualifies for priority as a geographical name and/or as a Community application. Regards CW

El 15 de julio de 2020 a las 18:11 christa@dottba.com escribió:

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 http://www.mmx.co/

M: +1 (604) 961-9460

Email: christa@mmx.co mailto:christa@mmx.co

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