My reading of the language is that if you opt for a .brand (spec 13) TLD you have to pay the fee for the .brand eligibility evaluation, or if you don’t have a qualifying trademark and want to opt for just a CoC exemption instead then you pay the fee for the CoC exemption evaluation. So it’s an either/or rather than a case of an applicant having to pay for both. Hopefully ICANN can confirm this, otherwise I agree with you, Jeff. In any case, we could probably try and make a language a little clearer in this section. Ashley Roberts Head of New TLD Consultancy Com Laude T +44 (0) 20 7421 8250 Ext 264 [cid:image001.png@01DBA33F.6C5A3580] <https://comlaude.com/> Follow us on LinkedIn<https://t-uk.xink.io/Tracking/Index/pRkAAGVfAADD_RQA0> and YouTube<https://t-uk.xink.io/Tracking/Index/bhkAAGVfAADD_RQA0> From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org> Sent: 01 April 2025 17:30 To: subpro-irt@icann.org Subject: [SubPro-IRT] Re: Apologies for Call Hit send too soon...just meant to say that with Communities, we should not be punishing them by making them pay for the commitment analysis, which was caused by ICANN's interpretation of its Bylaws (which some of us still do not agree with). On Tue, Apr 1, 2025 at 12:28 PM Jeff Neuman <jeff@jjnsolutions.com<mailto:jeff@jjnsolutions.com>> wrote: All, Sending apologies for the call later. I have a conflicting obligation. That said, I put comments into the TLD Type document, mostly on the unexpected added fees for Brands and Communities. These make no sense to me at all. 1. Brands - We are saying they have to pay for an evaluation to see if they are eligible to get a .brand. And then it says they have to pay for a Spec. 9 Code of Conduct Exemption as well....even though the Code of Conduct exemption is embedded in Spec 13 (Section 3). Thus, if they qualify to be a brand TLD, then there is No Need for a separate evaluation OR a separate fee? Sure, if they fail eligibility, then you can ask the applicant if it wants the Spec 9 evaluation and then it pays for that. But if it passes eligibility, then no fee and no separate code of conduct evaluation. 2. Communities - Wow, we are really hitting them hard. Not only are they going have to pay for the CPE, which can be a good chunk of change, but then we are also going to charge them for the privilege of putting their policies into Spec 12. Right now, a provision was added that states that after a Community passes CPE, it needs to pay a Registry Commitment Evaluation fee so that ICANN can figure out what can go into Spec 12. -- [https://s3.us-east-1.amazonaws.com/clio-manage-prod-us-a-public-objects/acco...] -- [https://s3.us-east-1.amazonaws.com/clio-manage-prod-us-a-public-objects/acco...] ________________________________ The contents of this email and any attachments are confidential to the intended recipient. They may not be disclosed, used by or copied in any way by anyone other than the intended recipient. If you have received this message in error, please return it to the sender (deleting the body of the email and attachments in your reply) and immediately and permanently delete it. Please note that Com Laude Group Limited (the “Com Laude Group”) does not accept any responsibility for viruses and it is your responsibility to scan or otherwise check this email and any attachments. The Com Laude Group does not accept liability for statements which are clearly the sender's own and not made on behalf of the group or one of its member entities. The Com Laude Group is a limited company registered in England and Wales with company number 10689074 and registered office at 28 Little Russell Street, London, WC1A 2HN England. The Com Laude Group includes Nom-IQ Limited t/a Com Laude, a company registered in England and Wales with company number 5047655 and registered office at 28 Little Russell Street, London, WC1A 2HN England; Valideus Limited, a company registered in England and Wales with company number 6181291 and registered office at 28 Little Russell Street, London, WC1A 2HN England; Demys Limited, a company registered in Scotland with company number SC197176 and registered office at 15 William Street, South West Lane, Edinburgh, EH3 7LL Scotland; Consonum, Inc. dba Com Laude USA and Valideus USA, a corporation incorporated in the State of Washington and principal office address at Suite 332, Securities Building, 1904 Third Ave, Seattle, WA 98101; Com Laude (Japan) Corporation, a company registered in Japan with company number 0100-01-190853 and registered office at 1-3-21 Shinkawa, Chuo-ku, Tokyo, 104-0033, Japan; Com Laude Domain ESP S.L.U., a company registered in Spain and registered office address at Calle Barcas 2, 2, Valencia, 46002, Spain. For further information see www.comlaude.com<https://comlaude.com>