I disagree with this approach. ASP applications already have less risk than other applications because of all of the financial (and other) assistance they receive. No application should be risk-free from
a cost perspective as this will just encourage abuse. While the goals of the ASP program may be laudable, as I have said before, it is not a natural right to operate a TLD and not everyone should be operating a TLD. If you can’t even take the reduced cost
risk associated with an ASP application then you probably can’t afford to operate a TLD, which involves with significant costs and obligations
after the application period is over which isn’t covered by ASP. Creating a risk-free system for ASP applicants will result in abuse of the program and/or unqualified applicants applying for TLDs, both of which are a security and stability issue.
Marc H. Trachtenberg
Shareholder
Chair, Internet, Domain Name, e-Commerce and Social Media Practice
Greenberg Traurig, LLP
360 North Green Street | Suite 1300 | Chicago, IL 60607
T +1 312.456.1020
M +1 773.677.3305
trac@gtlaw.com | www.gtlaw.com
| View GT Biography
![]()
![]()
From: John Matson via SubPro-IRT <subpro-irt@icann.org>
Sent: Friday, September 5, 2025 6:06 AM
To: Lars Hoffmann <lars.hoffmann@icann.org>; Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [SubPro-IRT] Re: Public Comment Re: Replacement String for ASP
*EXTERNAL TO GT*
Would it make sense to consider revising the ASP Refund amount up to 100% though a very limited time once contention sets are known or some other clear milestone? This would eliminate the cost risk for an ASP
applicant of losing funds which was stated as a reason why some are still not willing to apply?
John