Per the previous call, I said I would send around the draft text of this proposed statement so that we could have another look at it prior to sending it on. United Domains is still making the offer, and I altered the language in the first paragraph to address the timing issue. So far the only comment on this has been from Wendy Seltzer, appended here (the sentence in question appears between brackets in the draft text). Wendy's comment: "I agree with the general sentiment of avoiding confusion -- more, and more accurate information is better. I disagree with the sentences below, specifically as regards "artificially creating demand." If the service acts as an indication of demand, we can dispute its accuracy (lots more people may "pre-register" if its free than might pay money for a registration, or vice versa, they might not want to show their hands early) but I don't think it's insidious for that reason. I see nothing wrong with letting people try to measure or justify demand for new TLDs however they like." Please offer any additional feedback by Friday, and I will plan to send the statement out officially on Monday. --------DRAFT LANGUAGE BEGINS HERE------------- To: ALAC and ICANN Board From: North American Regional At-Large Organization (NARALO) Subject: Pre-registration of TLDs The NARALO observes that at least one ICANN-accredited registrar, United Domains, is offering what it calls "Free nTLD pre-registration" (see https://www.uniteddomains.com/ntld/pre-register-new-domains). United Domains began the offer in advance of ICANN's new gTLD decision in Singapore, and it continues afterwards, in expectation of greater availability in October 2012. While United Domains says the pre-registration service is free and non-binding, the NARALO is concerned the offer of such a service [could create artificial demand which could then be used to justify additional rounds of TLD creation and release, or might serve to confuse consumers.] The NARALO wishes to remind ICANN that approximately 10 years ago, the announcement of pre-registration for new top-level domains (such as .aero, .coop and so-on) prompted the U.S. Federal Trade Commission to issue a consumer alert (http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt084.pdf) that said, in part, "Some registration services are guaranteeing new top level domain names or promising preferential treatment in the registration process.... "But, the agency cautions, these offers may be misleading. "The FTC advises consumers to protect themselves by: ...Avoiding any domain name pre-registration service that guarantees particular top level domain names or preferential treatment in the assignment of new top level domain names.." The NARALO is aware the situation is different now than it was then and that United Domains and others provide substantial disclosure information about the nature of the pre-registration program. The NARALO also recognizes that the FTC action at the time was thought by some in the Internet community to be excessive and alarmist. Therefore, the NARALO recommends that, through ALAC, ICANN undertake public communication that makes clear what, exactly, consumers and others might expect from "pre-registration." It should be the organization that administers the domain name system, not the agents of domain sale, who should be defining the nature of Internet "real estate" in the public interest.