This is the wiki page for At-Large comments on "Limited Public Interest" and "Community Objection" Grounds for the applied for string ".book" for the 60 day Application Comment Period from June 13 to August 12 2012 and for the 7 month Objection Period from June 13 to mid-January 2013.

The ALAC has standing to object to a gTLD application on "Limited Public Interest Objection Grounds and community objection grounds 

At-Large Comments for evaluation panel's consideration (String Similarity, DNS Stability, Geographic Names, Technical & Operational Capability, Financial Capability, Registry Services, Community Priority) for the 60 day Application Comment Period can be found at the At-Large Comments on gTLDs for Evaluation Panels Consideration Workspace

These At-Large comments will be reviewed by the gTLD Review Group for drafting a formal comment for ALAC approval during July 26-18 2012 in time for possible submission by ALAC to ICANN within the Application Comment Period.

ICANN's Public Comments during the Application Comment Period can be viewed at


The following are the applicants for the ".book" applied for string.

StringApplicantLocationCommunityPrimary ContactContactEmailApplication ID
BOOKDotBook, LLCUS--Ms. Annie
BOOKDouble Bloom, LLCUS--Daniel Schindlerdoublebloom@donuts.co1-1361-60591
BOOKAmazon EU S.à r.l.LU--Ms. Lorna Jean
BOOKNU DOT CO LLCUS--Jose Ignacio Rascor@straat.co1-1296-97422
BOOKBronze Registry LimitedGI--Mr. Geir Andreas Rasmussenicanntas33@famousfourmedia.com1-1217-96477
BOOKGlobal Domain Registry Pty LtdAU--Mr. Jeremy Ebbelsjeremy.ebbels@ariservices.com1-1132-20461
BOOKCharleston Road Registry Inc.US--Sarah Falveytas-contact@google.com1-1099-17603
BOOKTop Level Domain Holdings LimitedVG--Mr. Antony Van CouveringTas.Minds.Machines.6@gmail.com1-1038-7319
BOOKR.R. Bowker LLCUS--Ms. Sharon L LubranoSharon.Lubrano@bowker.com1-1020-75316




NOTE: You must be logged in to post comments. If you do not have a wiki account, please email your comment to the gTLD RG group at

The gTLD RG reserves the right to remove comments that do not adhere to ICANN's Expected Standards of Behavior and Open Comment Forum Process and Standards.

  • No labels


  1. Limited Public Interest Grounds

    Please reply under this comment thread if your comment is on Limited Public Interest Objection Grounds

  2. Community Objection Grounds

    Please reply under this comment thread if your comment is on Community Objection Grounds

      1. The comment by InternetNZ appears not to be against the .book string, but rather against the concept of private TLDs as applied for by Amazon. Indeed, the comment is against the business model rather than the string (indicating .book as only an example of the strings applied for by Amazon). Since the Amazon application is not a "community" designated application, the Community Objection Grounds (as offered to the GAC, ALAC and Independent Objector) cannot be applied against it.

        In any case, I oppose the  InternetNZ complaint on its merits and strongly recommend that ALAC not act upon it.

        Out of the hundreds of unique strings being applied for under the ICANN new gTLD program, a small number of them are proposed to be single-registrar (what InternetNZ inaccurately describes as "closed"). It is absurd to suggest that choice would be limited because a handful of new gTLDs choose not to use the traditional ICANN model of selling second level domains.

        InternetNZ's comment suggests that gTLD string applications ought to be assessed not only based on the string as how they are to be used. Such a change indicates a substantial modification in ICANN's mission which has been limited to evaluating the stability and security of domain names themselves. Its last effort dabbling in TLD content – regarding the .XXX TLD – was a legal, publicity and operational nightmare, from which I hope lessons have been learned. ICANN has demonstrated many gaping holes in its ability to evaluate and assure regulatory compliance with rwithin its current limited scope; I believe that very little public support would exist in having that scope expand to evaluation of business models.

        Furthermore, there is absolutely no reason that the registrar-reseller sales model of distributing second-level domains is unassailable and that innovative alternatives must be objected to. A single-registrar, single owner model of TLD could potentially eliminate name-squatting and defensive registrations, while making a single well-known multinational entity responsible for any abusive activity in the TLD. It could also offer innovative approaches to domain use, including short-term "leases" of names (for events, as example).

        Amazon's single-owner model could introduce any of these innovations. Or none of them. Or some not yet conceived – that's practically the definition of "innovation". As such, these alternatives should be free to be tried. If nobody wants them, the TLDs will fail – as, undoubtedly, will countless other TLDs. However, if alternative models succeed, they have the potential to challenge ICANN's core assumption that every name and common word is but a mere commodity to be bought and sold. In clinging to the status quo the InternetNZ comment erroneously labels "open access" what is actually "open to the highest bidder", a current distribution model that does not work well for all existing users who may prefer a choice.

        But one things is clear. It does not serve the public interest to insist that all TLDs must conform to the current conventions of lower-level domain distribution. Alternatives and innovation must be not only allowed but encouraged, if the public interest is truly to be served by ICANN's gTLD expansion. After all, there will be plenty of "open" TLDs around for anyone who don't like Amazon's. With almost 2,000 applications in play, it's hardly a monopoly.

  3. Evan, perhaps I misread, but I didn't see the InternetNZ comment as objecting to the single registrar concept, but rather the proposal that 2nd level names would be made available only to Amazon and its subsidiaries. The single registrar was just Amazon's choice of implementation of the selective distribution rule.

    Regarding the merits of the overall comment, they are effectively saying that a TLD which has a generic meaning or is of generic interest should not be allocated to an applicant who plans to use it in a closed manner. That is a dandy rule that we could have made (although the implementation might have been challenging). But for better or worse, we do not have such a rule in the guidebook.

    However, after re-reading the guidebook section on the Community Objection, I was fascinated to discover that (as far as I can see), it is NOT just aimed at applications designated by the applicant as being a Community TLD. The objection must be filed by something considered to be a community, but there does not seem to be a restriction on which applications it can be used against. So (presuming I did not mis-read - a distinct possibility and I presume someone will correct me if so), if the International Community of Booksellers and Book Readers may well be able to file an objection against Amazon's application.

    1. Alan,  I think there's one word that makes all the difference. 

      Are the names available only to Amazon and its subsidiaries,  or only from them.  And whose law dictates that everyone using a 2LD must own it for a year...  or at all? 

      As for assignment of generic words, that ship has sailed. If it's wrong to have private ownership of common words, it's wrong at both the top and lower levels. ICANN decided long ago that common words could be a commodity, the gTLD program is merely an extension of that. 

      And ICANN also passed judgment on single registrar options (allowing them) in the recent Vertical Integration debate. 

      In any case, you've been around ICANN longer than I. You know it's incapable of doing anything dandy. And it's way too late to rethink this. This is what they created. 

    2. Hi, Alan, I believe your interpretation is correct - community objections can be filed by any community implicitly or explicitly targeted by an applicant for an applied for gTLD string, even if the applicant has not designated itself as community based. The AGB also says that  the objector must be an established institution associated with a clearly defined community.

  4. It seems to me that "privatization" of common words as top level domains is not a practice corresponding with current multi-stakeholders approach.

    Maybe it would be wise to evaluate some common rule for TLD - something like «Top Level Domains named in common words in UN official languages are to be ruled similarly to existing .com, or .org domains, named in common words of other languages - as .com.* or .org.* of corresponding countries»?

    1. You mean, like "museum"? Or "cat"?

      The precedent exists, yet there were (and are) no complaints about those "closed" TLDs. And nobody seems to have a problem with widespread commoditization of common words at the second level.

      So complaints about the same practice at the top level are both hypocritical and way too late.


      1. Yeah... Even more - maybe every word in Webster.  ;+))

        I guess there is a big difference between second and top level - first of all in responsibility.

  5. In my opinion, gTLDs are similar to ccTLDs with respect to how closed these domains are treated in most cases. By the way, Amazon is bidding against 8 more contenders.  

  6. I was asked by Dev to condense the InternetNZ comment since it has to be 1500 characters or less (including spaces). I wrote it as a summary of what I thought were the main points. Please add/change or re-arrange. Thanks:


    Condensed comments follows:

    This comment was submitted by the Internet New Zealand Inc (InternetNZ). InternetNZ is the membership-based, non-partisan, not-for-profit charitable organization responsible for the administration of the .nz ccTLD. InternetNZ indicated that their comment should be received on the basis of the “Community” objection grounds. 

    They claim that the new gTLD policy of private, closed registration – that is, of granting sponsoring organizations exclusive rights over gTLDs without obligating said organizations to open up registration of Second Level Domains (2LDs) to others – is anathema to the openness of the Internet, as well as a number of other fundamental principles embraced by them.

    They mentioned the .book gTLD application made by Amazon EU S.à.r.l as an example of such anticompetitiveness. In its application Amazon's stated that only it and its corporate subsidiaries would be able to register a 2LD under .book.

    InternetNZ infers that ICANN should introduce an 2LD registration policy to the new gTLD program. They emphasized that the role of openness has been fundamental to the Internet’s success and that internetNZ firmly believes that this should not change.


    Document Statistics:

    • Words: 179
    • Characters: 1174
    • Characters (excluding spaces): 999

    I have attached a copy of the original Amazon's application and highlighted the wording that internetNZ quoted from it. -> ICANN New gTLD Application - AMAZON.pdf


  7. By the way, after carefully reading the comments made by internetNZ they are not really complaining about .book Amazon's policy but the fact that ICANN does not have a policy against closed second level domains. They should have participated (I am assuming they did not) during the creation of the applicant's book. Also, I agree with Evan with respect that this is not a Community designated application.

  8. FWIW and while I remain convinced it is not the business of this group to 'revise and extend' comments, Eduardo's re-work of InternetNZ's content is neutral enough.

    You would have seen the questions I generated on the list in response to the first posting. Even as they were intended as grist for this discussion mill, these were also to telegraph my state of mind.  In case of a misinterpretation, here under, my position.

    This comment from InternetNZ does not rise to the threshold required for the RG to recommend a formal comment from the ALAC.  In the first place and like several others have already noted, the fundamental question it raised is whether there should be a complement of reserved strings comprised of common words and, whether closed ownership - or let's be more generic and say barriers to second level registrations by the registry rules - ought to be allowed.

    In the context of the RG's work, this is out of scope. As a fundamental matter, an intervention at this time risks an unwarranted 'a priori' intrusion in *a* perceived registry business model, which to mind remains outside the scope of the ICANN remit.  In fact, this plaint might be rationally construed as intent to shut the gate when the horse has already bolted.  

  9. I am generally in favor of formalizing the InternetNZ comment for ALAC's further consideration.  I do not view the ownership of generic TLDs the same as ownership of a generic 2dLDs and can see a strong policy argument from the Internet users point of view that any generic TLD should be open and not closed.  I am nor sure that InternetNZ or the ALAC qualifies as an institution with standing for this Community Objection but this is an interesting issue that needs clarification and will not be clarified if we construe the Community Objection requirement too narrowly.  I do think this is an issue appropriate to the At Large arena. 

  10. Thank you for the comments received. Below is the outcome of the gTLD RG August 6 conference call to discuss the comments received on this application as emailed sent to the ALAC and to the new gTLD WG on


    Dear All,
    The gTLD Review Group (gTLD RG ;
    received a comment on community objection grounds by InternetNZ, an
    ALS in APRALO, on the application by Amazon EU S.A.R.L for the applied
    for gTLD string "book" on July 26 2012.
    InternetNZ's comment was posted to the At-Large new gTLD Applications
    Dashboard Workspace at
    Several comments from At-Large, including members of the gTLD RG were
    received and posted on the wiki page at
    including a condensed version of InternetNZ's comment by gTLD RG
    members Eduardo Diaz and Yrjo Lansipuro.
    The comments by InternetNZ and others raises concerns regarding the
    availability of 2nd level domains under generic TLDs. Whether domains
    under such proposed generic TLDs should be available or "open" to the
    wider public or "closed" to the applicants applying for the proposed
    Because such concepts are outside the scope of the application for
    ".book" by Amazon EU s.a.r.l, the gTLD RG on its conference call on
    Monday August 6 2012 ( decided
    not to submit a comment on this application to the ALAC for possible
    submission to ICANN's new gTLD comment forum before the close of the
    Application Comment Period.
    However, given the concepts raised regarding the availability of 2nd
    level domains under gTLDs has policy implications that impacts
    individual Internet end users, the gTLD RG recommends that the issues
    raised be referred to the At-Large new gTLD Working Group
    ( for discussion and possible
    policy recommendations.