Hello IRT,

I had hoped to discuss this on a call, but have been asked to share to the list for discussion.  Please read and provide feedback as CPE is about to go to public comment.

There is a scenario where Community Priority could be gained by a very small group for a super generic string, which I don’t think aligns with the intention of providing this great advantage of avoiding ICANN auction via designation as a community.

For ease of reference, here is the overall scoring section:

1.6.1 Criterion 1: Community Establishment

This criterion relates to the community as explicitly identified according to statements in the application. The panel will seek to answer the following core questions in evaluating the application against this criterion:

• Organization (2 points): Is the applicant the organizing body for the community? If not, is the applicant able to demonstrate that the community is organized, with an organizing body(ies) relevant to the community or to each member category of the community?
• Engagement (1 point): Is the applicant able to demonstrate that there is active engagement with community members?
• Awareness (1 point): Is the applicant able to demonstrate awareness among and between community members of the identified community?
• Longevity (1 point): Is the applicant able to demonstrate the longevity of the community's pursuits, showing that they are enduring and sustainable rather than temporary?

Here is the scenario.

The application is for .coin, and the applicant represents a multigenerational family with the surname “Coin” .

The applicant Mr. Coin Sr.  has created an LLC and that LLC “Coin TLD” is the organizing body for the community “as defined by the applicant” (“My family, the Coin Klan is a community” says Mr. Coin).

Mr. Coin Sr. can claim the family including Ms. Coin, Mr. Coin Jr. and Sister Coin have appointed him and the LLC as the organizing body for their Coin community. 

They are actively engaged with each other, even on a daily basis (“Dad can I have a ride to the movies?” says Sister Coin. They then spend lots of time in the car interacting. They text each other every day).  

Clearly the entire family is fully aware of their community and know they are part of the Coin Klan. 

The Coin community was established generations ago and since Mr. Coin Jr. has two kids and is expecting a baby soon, they can demonstrate longevity, sustainability, and prove they are not merely a temporary Klan.

The opportunity for the Coin Klan to win .coin over any other applicant is real, but the delegation of a super generic string to a community such as The Coin Klan over any other applicant seems counter to the spirit of the recommendation.

Can we add some language that prevents this sort of opportunism? Should there be extra scrutiny or higher points required when a super generic string is in play?

Elaine