Thank you Jared for the references to other parts of the evaluation that could prevent the Coin Klan from obtaining community priority for a very generic string. I agree to the suggestion to highlight this AGB language prominently (at the top of the CPE document) to deter such applications. “The scoring process is designed to identify qualified community-based applications, while preventing both false positives (awarding undue priority to an application that refers to a “community” construed merely to get a highly desired generic word as a gTLD string)” (page 5). But, let’s say they are applying in good faith and wouldn’t be construed merely as applying to get a highly desired generic word as a gTLD string, because they are the Coin Klan and have the same “right” to the TLD .coin as any other applicant. Could you please explain how the Registration policies on eligibility disallow a “closed generic”? What’s the difference (and/or threshold)  between a “closed generic” and a “restricted” TLD? Eligibility (1 point): Is eligibility for registrants restricted? Who is qualified to register a domain in the TLD? Are there specific qualifications provided that entities or individuals must meet to be eligible as registrants by the registry? Thanks Elaine From: Jared Erwin <jared.erwin@icann.org> Date: Monday, February 10, 2025 at 1:48 PM To: "subpro-irt@icann.org" <subpro-irt@icann.org> Cc: Michael Karakash <michael.karakash@icann.org>, Lars Hoffmann <lars.hoffmann@icann.org>, Elaine Pruis <epruis@verisign.com> Subject: [EXTERNAL] Re: [SubPro-IRT] Re: Updated Draft AGB Section for Topic 34: Community Applications Caution: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thank you, Elaine and Lars. I want to add a couple of thoughts: Nexus would likely catch this type of issue, as the applicant appears to be using a string in a way that differs from common understanding. Based on the Nexus criteria, the applicant would likely receive a 1 (Partial Match) or 0 (Weak Match) on Nexus because of the following guidelines (page 10): Does the string identify a wider geographic or thematic remit than is related to the identified community? Does the string indicate a community of which the applicant is a part, but is not specific to the applicant’s community? Is the size or definition of the identified community consistent with the string? Regarding the Community Establishment criterion, while you provide examples of what the Coin family could say, it is unlikely that an expert panel would accept informal documentation of familiar interactions as sufficient evidence of engagement, awareness, or longevity. We have deliberately introduced very objective requirements for documentation for these sub-criteria (pages 6-9). Additionally, Lars’ reference to the definition of “generic strings” is important. Depending on how this family drafted their registration policies (which sounds like the TLD would only be used by members of the family or their business?), that would seem to constitute a “closed generic”, which would also not be allowed. With that in mind, I think there are a few things we could do to try to further address this issue: Nexus: Add a guideline to Nexus in the vein of asking whether a string that is clearly generic is being used in a non-generic way. Awareness: Add a guideline to Awareness related to whether individuals outside the identified community are aware of the community. Note that we have similar concepts with Community Endorsement: “Is the applicant able to demonstrate that there is relevant support or no relevant opposition from outside the community as identified? This may apply in cases where the applied-for string carries more than one meaning” (page 14) AGB Language: The text already includes the following: “The scoring process is designed to identify qualified community-based applications, while preventing both false positives (awarding undue priority to an application that refers to a “community” construed merely to get a highly desired generic word as a gTLD string)” (page 5). We could highlight this more prominently (at the top of the document) to deter such applications. Thank you again for your input on this complex topic. As Lars mentioned, we could discuss this in Seattle if the IRT feels this warrants further deliberation. Any updates to the language would be made after Public Comment 4. Best Jared From: "Pruis, Elaine via SubPro-IRT" <subpro-irt@icann.org> Reply-To: "Pruis, Elaine" <epruis@verisign.com> Date: Monday, February 10, 2025 at 08:33 To: Lars Hoffmann <lars.hoffmann@icann.org>, Michael Karakash <michael.karakash@icann.org>, "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Updated Draft AGB Section for Topic 34: Community Applications Thanks for the insight Lars, I hope we will have time to discuss in Seattle as I think this topic impacts a broad swath of the community and bringing these types scenarios to light may help set proper expectations for what CPE could look like. Elaine From: Lars Hoffmann <lars.hoffmann@icann.org> Date: Saturday, February 8, 2025 at 12:34 AM To: Elaine Pruis <epruis@verisign.com>, Michael Karakash <michael.karakash@icann.org>, "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: [EXTERNAL] Re: [SubPro-IRT] Re: Updated Draft AGB Section for Topic 34: Community Applications Caution: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thank you, Elaine, for your thoughtful contribution. For context, here is the existing definition, per Based RA (p. 102): “A string consisting of a word or term that denominates or describes a general class of goods, services, groups, organizations, or things, as opposed to distinguishing a specific brand of goods, services, groups, organizations, or things from those of others.” I think you make a valid point, but I am not sure that, under the current set of policy recommendations and implementation guidance, anything could be done to prevent the Coin klan from scoring highly in your described scenario. Determining the ‘right/best/most deserving’ community for a particular gTLD string will always remain somewhat subjective. Some may believe that the Coin klan constitutes a community and see no issue with your example. Others may argue that all those who use coins—real or virtual—are the true coin community and that the coin family should not be able to obtain the TLD via CPE. Alternatively, as you suggest, some may feel the term is ‘too generic’ and should not even be permitted as a community TLD. This reflects the broader challenge we have encountered when considering CPE: everyone knows what kind of community in their view should pass CPE. Because this knowledge is inherently subjective, we have so far struggled to establish objective criteria to determine which community applicant deserves a generic string over all other applicants. Perhaps we can dedicate some time to this topic during one of the Seattle IRT sessions and explore the issue further. Such a discussion may also help inform public comment input, which will be due about a month after ICANN83. Thank you, and I look forward to continuing the dialogue. Very best, Lars From: "Pruis, Elaine via SubPro-IRT" <subpro-irt@icann.org> Reply-To: "Pruis, Elaine" <epruis@verisign.com> Date: Friday, 7 February 2025 at 23:51 To: Michael Karakash <michael.karakash@icann.org>, "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Updated Draft AGB Section for Topic 34: Community Applications 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 From: Michael Karakash via SubPro-IRT <subpro-irt@icann.org> Reply-To: Michael Karakash <michael.karakash@icann.org> Date: Friday, February 7, 2025 at 8:31 AM To: "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: [EXTERNAL] [SubPro-IRT] Updated Draft AGB Section for Topic 34: Community Applications Caution: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear IRT Members, I’m sending here the updated draft AGB language for Topic 34: Community Applications (Community Priority Evaluation). Link to Google Doc Link to Clean PDF Link to Redline PDF This version includes the following changes/updates: Responses to IRT comments and updates based on comments, where applicable Quite a few editorial edits Clarification in Sections 1.1 and 1.2 regarding requirements for community applicants as it relates to community information and Community Registration Policies Several clarifications to the guidelines for each of the criteria, including on the required supporting documentation Clarification on the community endorsement scoring as to how an applicant would achieve points As noted previously, ICANN recommends that we push forward with Public Comment and that ICANN continue to review the CPE language once comments on the topic have been received. We would kindly request any further on anything the IRT believes does not meet the intent of a recommendation to be provided to us as soon as possible but no later than 13 February 2025. Thank you! Best, Michael