Hi George,

Thoughts:

It makes sense the vast majority of nTLDs have low/no sunrise registrations as they’re uptake has been low.

64% of nTLDs have less than 1,000 registered domains
85% have fewer than 10K registrations

All nTLDs are not created equal. It’s no surprise nTLDs that are expensive, have limited applicability, and/or are similar to other extensions see fewer Sunrise registrations.
Sunrise registrations are affected by many factors in consideration by registrants at any given moment (the economy, cash-on-hand, marketing plans, life of the brand, etc.).

In other words, just because we don’t see Sunrise registrations booming across all nTLDs doesn’t mean it isn’t a valuable tool where it is applicable. It’s rather like a product warranty: you may decide to cover everything, only what you can easily afford, or to skip it altogether. The fact that many people opt out of the warranty doesn’t invalidate the concept.

Sunrise is relatively simple and provides a reasonably effective initial bar to bad behavior.

Rather than eliminating a feature that is often useful as a first measure of protection & not overly-burdensome, we should tweak Sunrise & move on.

O: +1 81-ModernIP

C: +1 818.209.6088

-----Original Message-----
From: gnso-rpm-wg-bounces@icann.org [mailto:gnso-rpm-wg-bounces@icann.org] On Behalf Of George Kirikos
Sent: Thursday, August 10, 2017 12:44 PM
To: claudio di gangi <ipcdigangi@gmail.com>
Cc: gnso-rpm-wg <gnso-rpm-wg@icann.org>
Subject: Re: [gnso-rpm-wg] 99%+ reduction in sunrise utilization rate per TLD supports EFF call for elimination of sunrise

Claudio:

Costs of a sunrise also scale as you increase the number of gTLDs. Are new gTLD registries paying on a per domain name (variable cost per domain name) only? Or are there fixed costs too? Are sunrise periods (which delay launch of GA) shorter, if there are more TLDs? Or are they fixed in length? Are there equal amounts of "good" domain names in those new gTLDs, or are the gamed sunrise domains representing a higher proportion of the "good" ones, as one scales?

If 1,000,000 new gTLDs are launched, clearly any sunrise period is *pointless*, as TM holders are going to focus nearly entirely on *curative rights.* That was my point --- they're *already* doing that, shifting to curative rights, by decreasing their usage of sunrise periods. Thus, the costs of eliminating sunrise period are lower, because of that reduced usage (or, in other words, the benefits of retaining that sunrise period are low).

That's why it's time to sunset/eliminate the sunrise period mandate -- it outlived its usefulness as a tool, as the numbers show. It's only there to "shear the sheep", so to speak (i.e. soak TM holders who are highly risk averse, and don't know any better; i.e. bad insurance, like the folks who buy those electronics "Extended Warranties").

As for those 1,000,000 new gTLDs, realize that if sunrise was eliminated, there'd also be 1,000,000 landrushes --- any brandholder that had coveted a name could still get it, on an equal playing field with everyone else, instead of jumping ahead of the line.

Sincerely,

George Kirikos

416-588-0269

http://www.leap.com/

On Thu, Aug 10, 2017 at 1:24 PM, claudio di gangi <ipcdigangi@gmail.com> wrote:

> George,

> I'm going to use an extreme example to illustrate my point.

> If 1,000,000 new gTLDs are launched in the next round, how many

> Sunrise registrations do think there should be order to reach the "success"

> threshold?

> Best,

> Claudio