The Spec 12 evaluation is only about ICANN being able to enforce that condition. It’s not related to gaming, which is what CPE is designed to prevent. 

A possible gaming applicant would be benefitted by passing CPE and then not being required to add a Spec 12 commitment, simply by forfeiting the Spec 12 evaluation fee. 




Rubebs



Em 1 de abr. de 2025, à(s) 13:55, trachtenbergm--- via SubPro-IRT <subpro-irt@icann.org> escreveu:

I also have a conflicting obligation.
 
I agree with Jeff on point 1 below.  I am fine with the fees for Community Applications and think that the bar should be high to prevent gaming.
 
Best regards,
 
Marc H. Trachtenberg
Shareholder
Chair, Internet, Domain Name, e-Commerce and Social Media Practice
Greenberg Traurig, LLP 
77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 
T +1 312.456.1020 
M +1 773.677.3305
trac@gtlaw.com | www.gtlaw.com  |  View GT Biography
 
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From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org>
Sent: Tuesday, April 1, 2025 11:29 AM
To: subpro-irt@icann.org
Subject: [SubPro-IRT] Apologies for Call
 

*EXTERNAL TO GT*

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.  
 
 
 
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