[EURO-Discuss] Proposed Euralo statement on the gTLD Applicant's guide

Wolf Ludwig wolf.ludwig at comunica-ch.net
Mon Jan 26 06:36:57 EST 2009


Thanks a lot, Patrick, for all your efforts on this EURALO statemement 
-- what I find consistent and I fully support.

Best,
Wolf


 Patrick Vande Walle wrote Sun, 25 Jan 2009 17:47:
>Dear colleagues,
>
>Please find below and as an attachment, a draft Euralo statement on the
>gTLD Applicant's guide
>
>Regarding the process: the public comments period is over. However, the
>ALAC is able to make comments directly to the board. The Euralo comments
>could be an appendix to the overall ALAC statement.
>
>I have also included a draft ALAC statement. While the ALAC text may
>still change a bit in wording, I expect the main ideas to remain. Hence,
>I drafted the Euralo text to mention only the things that do not appear
>in the ALAC statement.
>
>Please comment to the list,
>
>Patrick
>
>
>
>Euralo additional  Statement regarding the First Draft of the Applicant
>Guidebook and Associated Document
>
>The European At-Large Regional Organization supports the general ALAC
>statement below. Additionally, we nevertheless wish to insist on several
>aspects.
>
>The EURALO does not support recent calls for a delay to the new gTLD
>process, we are particularly concerned about any delay to the
>introduction of IDN TLDs, both generic and country code and strongly
>oppose any further barriers to their introduction.
>
>We also note that the process is conducted largely in English, and the
>complex and lengthy documentation that must be understood before making
>an application introduces a strong bias toward English speaking
>applicants. International competition will not be enhanced through
>processes that disadvantage the non-English speaking world.
>
>Further, a rigid registry/registrar separation really does not fit into
>the reality of smaller applicants, especially non-profit. In these
>cases, the burden of having to cope with ICANN-accredited registrars
>might simply kill the registry, while registrars might have little
>interest in reselling or promoting the TLD.
>
>Also, for TLDs aimed at specific geographically-defined communities,
>especially if the TLD is an IDN, there might be a serious scarcity of
>ICANN-accredited registrars offering services in that part of the globe,
>or there might even be none. We suggest that registries should be forced
>to use registrars only when their size goes beyond certain thresholds
>(e.g. 50k-100k domains).
>
>The Euralo is also asking to have a different approval process for the
>geographical, community bounded, non-commercial, not-for-profit gTLD's.
>They should have the opportunity to enter their proposals with a low
>entry fee, which should be proportional to the intended size of the TLD
>(registry would pay extra fees once they grow and move from one size
>group to the following one).
>
>
>ALAC Statement to the Board of ICANN on the First Draft of the Applicant
>Guidebook and Associated Documents - V1.
>
>Firstly, the ALAC wishes to make clear that the At-Large community as a
>whole is not of one view with respect to many elements of the New gTLD
>programme.
>There are a number of members of our community who are sceptical of the
>need for new gTLDs at all – conversely, there are others who believe
>that new TLDs are a great thing and that the existing process has gone
>on much too long and should be expedited; between these views are
>various intermediary views.
>
>However, with respect to the specifics in the Applicant Guidebook and
>associated documents, the community does have a number of strong views
>that are generally shared. They are as follows:
>
>Firstly, with respect to the fee for a new TLD application, and the
>yearly fee for retaining the delegation, we find that the rationale is
>at best tenuous (for example, why is it that ICANN needs to recoup costs
>expensed in previous years for the new gTLD programme if it really
>doesn’t wish to profit from the new TLD process?). More fundamentally,
>the one-size-fits all fee structure skews the entire programme in favour
>of developed world, for-profit TLDs and constitutes a major barrier to
>entry for community-based TLDs and developing world applications. This
>is not acceptable. The fee structure should encourage new types of TLDs
>and not just those wishing to try and create the “next .com”.
>
>Secondly, while ICANN’s compliance processes are improving slowly, they
>are far from robust for the existing handful of TLDs; they are certainly
>inadequate for the hundreds of new TLDs that the applicant guidebook
>estimates will result from the first application round. We do not see
>that the new TLD process has learnt any lessons from past problems with
>respect to ongoing TLD operations – this must be remedied in a way that
>the ICANN community as a whole finds persuasive and comprehensive.
>
>Thirdly, we do not find evidence that ICANN understands that new TLDs
>should be of benefit not just to the operator, but also to the public at
>large. The objective of ICANN is not simply to grow an ever-larger
>market for domain names – it is to provide a venue for administration of
>a global critical resource for the benefit of the global public. This
>concept is almost entirely absent from the current process. Where are
>the mechanisms to help ensure that unscrupulous or criminal elements
>cannot almost effortlessly continue the abuses of the TLD space in new
>TLDs that they have been doing in existing TLDs – abuses that are a
>continuing and growing concern worldwide?
>
>Fourthly, the ALAC has made very clear our strong objections to
>so-called “morality and public order” objections being any part of the
>new TLD process. ICANN is not an appropriate body to have any view on
>such matters, whether directly or indirectly. We find that the
>incomplete elements related to this are entirely insufficient and we
>call upon ICANN to make public all details related to its investigations
>to date with respect to this objection. It is very clear that what is in
>the guidebook is only a tiny part of what ICANN actually knows.
>Additionally, we find the idea that the International Chamber of
>Commerce would act as arbiter of these objections absurd. Until the
>entire process related to this objection is made clear, it is entirely
>inappropriate and irresponsible to be choosing a dispute resolution
>provider to handle them.
>
>ALAC also believes that allowing a first TLD round to have hundreds of
>applications is completely irresponsible.  This is a major new area of
>work for ICANN; the first round should be reserved for those applicants
>who can demonstrate that they have been working on their applications
>for a considerable time (of which there are quite a few). After that
>round is completed, the process can then be fine-tuned to implement the
>lessons learned so that subsequent rounds can allow many more applicants
>to be handled expeditiously and transparently.
>
>Finally, we have seen no evidence whatever that ICANN has a plan to
>handle the massive amount of new work that this programme will create.
>Considering the problem that the organisation has executing on its
>existing responsibilities, we believe that a comprehensive resourcing
>plan for the New GTLD programme must be a part of the consultation
>process on the application processes themselves.
>
>In closing, we wish to make clear that as an Advisory Committee to the
>Board, we expect not only to receive confirmation that the Board has
>received this Advisory, but to see evidence that the board has actually
>discussed the advice we have provided and a written response to make
>clear the Board’s thinking on this issue. Indeed we believe that this is
>how advice from all Advisory Committees should be treated. 
>
>We thank you in advance for your thoughts on this communication and we
>are at your service if you have any questions regarding it.
>
>
>

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Digitale Allemd
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EURALO
https://st.icann.org/euralo/index.cgi?euralo_icann_at_large_europe




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