ICANN Staff proposal

Comments on proposal

Benefits of the Plan

We think the plan is beneficial both to potential applicants and to ICANN.

To ICANN, it means that the corporation will have a reference of a clear number of potential applications, allowing it to size its operations, both administrative and technical. It will allow root server operators to plan ahead the needed resources in order to serve the root zone file. It will also allow the community to identify if there is a need for a finer categorization (and segmentation) of the applications. Different categories could follow slightly different paths through the application process, and possibly make it more efficient. GeoTLDs, single owner/brand TLDs, community and open TLDs are all different categories that deserve a different treatment. Other categories may appear as the result of the EOI call.

To potential applicants, it will mean that they will be able to have a clearer view of the landscape, and either

  • tune their applications accordingly
  • find ground to submit a common proposal with other applicants in case of string contention
  • or throw the towel entirely, with not much financial damage

Once the landscape will be more or less set, it will be easier for potential applicants to convince investors to financially support their application.

Communication Period

The At-Large believes a significant communication effort needs to be undertaken to inform all possible participants on the new EOI process, as described in the staff proposal. It is of paramount importance that the whole exercise is not perceived as an insider's game. A lengthy and detailed outreach process is needed before the round begins. The EOI will be the only chance applicants will get. Information about the process must be made very widely available before it begins.

Mandatory character of participation in the EoI in order to file a gTLD application

The At-Large believes that the participation in the EoI should be a pre-requisite to file a full application later. This will allow potential applicants to develop their proposal without running the risk of being outplayed later on by late-comers with big pockets.


The At-Large believes that the proposed fee of $55,000 is too high for some potential applicants, especially those which target small communities or are located in less-favoured countries. This issue was already raised by the GAC in the context of the DAG, and has found no satisfactory answer up to now. We believe ICANN should not have an ideological position on which TLD model is best, by setting high fees that will de facto eliminate a lot of possible submissions that do not fit into the mould set by the DAG. In this context, the At-Large supports Avri Doria's comments submitted earlier. Making the process expensive is not in the public interest.

We believe that one of the goals of the EoI process is to allow prospective applicant to raise financial support for their application. It should not be assumed that potential applicants are already fully funded. Many potential applicants still have difficulties convincing potential financial backers, as they cannot demonstrate they have a reasonable chance of actually running the TLD.

This is why the At Large suggests to have different levels of fees, according to criteria collected from the EOI. Several models are possible.

  • There could be a fixed, reduced fee for not-for-profit and small community applications under the EOI, in which case the At-Large suggests it should not be above USD 25,000.
  • Some applicants could be exempt from any fee under the EOI (later full application fee still to be decided.) It would be a class of applicants self-identifying via their business plan, explaining target registrant "audience", expected number and registrant fee (some revenue/user number threshold might need to be identified). If the organization later exceeds the revenue/user numbers, they would pay some retroactive penalty fee.

This should allow less wealthy applicants to submit a proposal in the framework of the EoI, while at the same time prevent frivolous applications. Regardless of which system of rebate is put in place, the terms should be transparent and published ahead of the EoI process, and not be granted on a case-by-case basis in a non-transparent manner.

The money collected during the Expression of Interest process would need to be placed in escrow, and later released t to ICANN when Phase1 of application process starts.

The rules under which a refund would be possible need to be clearer, specifying the circumstances where refund will occur and when it will not.

Publication of EOI Information

The At-Large believes it is necessary to publish a minimal set of information. The goal is two-fold:

  1. Allow prospective applicants to settle agreements with potential competitors ahead of the application process, if needed.
  2. Allow ICANN and its community to identify the different categories of applications, that may end up following slightly different paths during the application process. This would allow to have optimal processes in for different categories of applications. In this respect, we think we need to identify the following criteria:
    1. Commercial vs not-for-profit applicants
    2. Community vs open TLD applications
    3. Geographical-based TLD (city, etc)
    4. Single owner / Corporate or Brand TLD

In addition to the above information, the Expression of Interest submission should also include the proposed TLD string and the name of the applicant.


We encourage ICANN to go ahead in the direction set by this proposal, keeping in mind the comments above. In all cases, policies should be consistent and not developed specifically for the applicant and their strings. We need a consistent policy process going forward so that applicants to the EOI has a good level of certainty that their application will go through if they meet the clearly-defined, objective criteria.

However, the At-Large suggests that the Board takes no decision at its February meeting and has further discussion with the community on this issue at the Nairobi meeting.

1. I believe the EOI applications should be made public after closing, so the community can evaluate these strings.

2. I support lowering the fees for selective applications. For example, community-based applications should be lowered to 25,000 while commercial applications can remains at 55,000.

3. The money to be place in escrow, that will be release to ICANN when Phase1 of DAG starts, and not given to ICANN immediately.

4. ICANN should make the "refund" rules clearer, specifying the circumstance where refund will occurs and when it will not.

-James Seng

contributed by james@seng.sg on 2010-01-10 13:35:23 GMT

This EoI will be also usefull for Internet end-users :
1/ to have a clearer view of the landscape
2/ to demonstrate the real need of categorisation (and segmentation) of the possible extensions.
We already have defacto Geo TLD category - including cities - (GAC involvment), Corp or Brand TLD category (IP and companies involvment)...
Segmentation between Community/Non community TLDs and between For Profit/Non For Profit...

I would like also that we (as end-users rep) start a discussion on Commun Names (or Dictionay Names) ome of them could be of (very) hight value.


contributed by sebastien.bachollet@isoc.fr on 2010-01-11 13:59:32 GMT

About the cost of the expression of interest, perhaps we should suggest that small, non-commercial applicants be exempt from any fee under the EOI (later full application fee still to be decided.) It would be a class of applicants self-identifying via their business plan, explaining target registrant "audience", expected number and registrant fee (some revenue/user number threshold might need to be identified.)

And perhaps if the organization later exceeds the revenue/user numbers, they pay some retroactive penalty fee.

I am still not sure that the EOI should be used as a means to sort out competing applicants. Or anything trademark related.


contributed by ajp@glocom.ac.jp on 2010-01-17 17:06:21 GMT

If there is to be an EOI round, then there must be a lengthy and detailed outreach process before the round begins. The EOI will be the only chance applicants will get. Information about the process must be made very widely available before it begins.

Except for the possible introduction of classes of strings, policies should be consistent and not developed specifically for the applicant and their strings. Need a consistent policy process going forward.

contributed by ajp@glocom.ac.jp on 2010-01-21 09:28:54 GMT

I just took notice of EOI - sorry about that, too busy for dot Nippon selection issue which has been a good struggle - .
In Japan, several city governments are now considering how to proceed with city TLD, or geoTLD, without having clear
strategy. This EOI, if implemented correctly, may facilitate the policy process for these local governments (eg Tokyo,
Kyoto, Osaka) to consider and to prepare. Yet, as ALAC draft indicates, there should be enough communication
time and outreach efforts from ICANN end, to make many local governments to be aware of such process.
I also strongly supports lowering the application fee, and also may make clear rules for refund should they cancel the application due to their local governance (I mean
citizens or local governments might decide to withdraw the application after EOI).

My 2 cents,


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