Mawaki: My comments on the document "2.5.1.1 ICANN will make a preliminary determination on whether the application complies with the string requirements and may seek expert advice in order to make its preliminary determination." No. This is a recipe for further expansion of ICANN into an enormous bureaucracy. ICANN must have a distinct list of non-allowed strings and any fool should be able to check it to determine what is and is not allowed. Anything that requires "expert advice" at this stage is by definition a bad policy. E.g., if you don't allow one-letter strings, that is a very easy rule to formulate and apply. "2.5.2.1 The gTLD string should not be confusingly similar to an existing TLD string. Confusingly similar means there is a likelihood of confusion on the part of the relevant public." This is silly. The draft uses a word to define itself (confusing). This should be better specified to restrict its application ONLY to visual similarities of the sort that would lead to typo squatting; e.g., .com, .conn. "2.5.2.4 The string should not... be in conflict with national or international laws or cause conflicts with public policy [for example, controversial, political, cultural religious terms]. (Develop text related to public policy issues with GAC assistance)." Any elimination of "controversial" words is completely unacceptable from a free expression perspective. Either it is against the law or it is not. There is no "public policy" middle ground which means "it is not illegal, but we (governments or other power holders) just don't like it." Please put an end to this nonsense, MAwaki. "2.7 An applicant must demonstrate that they have the capability to operate a new gTLD that meets the minimum technical criteria to preserve the operational stability, reliability, security, and global interoperability of the Internet." This was obviously written by someone who knows nothing of how DNS operates. There are no "Minimal technical criteria" for a TLD nameserver that will "preserve the operational stability, reliability, security and global interoperability of the Internet." This is an absurd conjunction of phrases. One part of it calls for minimum technical criteria that apply to one TLD nameserver, the other calls for sweeping global assurances that apply to the entire Internet. You can specify that TLD nameservers follow specific implementation standards. You can ask that they do not take actions that threaten the entire Internet. But you can't make them the same requirement. Get the engineers on the Council to laugh this out of the house and come up with a meaningful formulation. "2.8 The applicant must provide a financial and business plan that provides an assurance that the applicant has the capability to meets its business ambitions." This is stupid, too. There can be no such assurances in the real world. Either this criterion rules out ALL start-ups with an innovative idea, or it is meaningless. ICANN has no business making TLD decisions on the basis of business plans. ICANN is not a venture capital company. ICANN can only reasonably ask for the possession of a certain amount of capital, say about $100,000. Entire section 3: This is nonsense. What happened to auctions? If you have two or more commercial applicants bidding for the same TLD string the obvious solution is to hold an auction. It is also the fairest, quickest, and most efficient way. I know that our constituency has favored auctions for commercial TLDs, and that registrars have, so why has this idea disappeared? What you have here is a recipe for endless beauty contests and incredible FCFS wars. Beauty contests is a method we KNOW doesn't work. It has consumed enormous resources and produced bad decisions and alienated almost everyone involved in it. Moreover, the reliance on FCFS is really, really idiotic in this context. Can you imagine, given the way registrars have developed extensive software tools to contend for expoiring domains, how much will be invested in submitting TLD applications, and how inundated ICANN will be with these requests? >>> Mawaki Chango <[log in to unmask]> 9/14/2006 6:29:40 PM >>> Attached, the "Amsterdam report" in progress from the staff. Constructive and focused comments are welcome. Mawaki --- Liz Williams <[log in to unmask]> wrote: > To: [log in to unmask] > From: Liz Williams <[log in to unmask]> > Subject: [gtld-council] GNSO PDP Dec 05: Draft Recommendations > Summary > Date: Thu, 14 Sep 2006 15:31:51 +0200 > > > Colleagues > > Please find attached a DRAFT Recommendations Summary. It is a > working document which will be refined and completed as the > Committee's Final Report is prepared. > > If you have comments or questions, please come back to me. I would > > appreciate very much specific editing or contextual changes -- > please > identify the recommendation number you are referring to send me > specific text. I will collate all the comments from the group and > > work out the best way forward. I have read all the comments which > > have been circulating on the many lists and will work towards > incorporating those where there is majority agreement. > > I will have this document posted as a working document on the GNSO > > website. > > Kind regards and, of course, any questions please ask. > > Liz > > > ..................................................... > > Liz Williams > Senior Policy Counselor > ICANN - Brussels > +32 2 234 7874 tel > +32 2 234 7848 fax > +32 497 07 4243 mob > > > > >