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

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.  

--