This is the wiki page for At-Large comments on "Limited Public Interest" and "Community Objection" Grounds for multiple gTLD strings by IT for Change, India for the Application Comment Period from June 13 to September 26 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 September 11 - September 15 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 http://newgtlds.icann.org/en/program-status/application-comments
9 Comments
Dev Anand Teelucksingh
Limited Public Interest Grounds
Please reply under this comment thread if your comment is on Limited Public Interest Objection Grounds
Dev Anand Teelucksingh
Comments received by IT for Change, India on multiple gTLD applications
comments-by-IT-for-change-sept11-2012.pdf
Dev Anand Teelucksingh
Community Objection Grounds
Please reply under this comment thread if your comment is on Community Objection Grounds
Evan Leibovitch
On a personal level, I am extremely sympathetic to, and agree with many of, the concerns expressed in the objection by "IT for Change". I could easily see myself advocating for its policy goals. However, given the current process it is extremely doubtful that this objection is in scope, and it contains some factual errors in its assumptions:
Most specifically, this gTLD expansion program does not mark the introduction of strings longer than three characters, but is rather a massive expansion of an existing program. The group did not seem to have a problem with the existing use of ".aero", ".name" and ".museum", therefore the principle of objecting to all strings longer than three characters has long been mooted. The relative failure to date of three-letter TLDs such as ".pro" and ".biz" indicate that three-letter TLDs did not provide the level of domain expansion/relief that appears to be sought.
Furthermore, this objection appears not to be against any single application but indeed against all applications for strings that are dictionary words or longer than three characters. This is far too broad an objection to be applicable for the ALAC-driven review process; indeed, it indicates an objection to policy as opposed to any specific application. While I share the concerns and have expressed many myself, the ability to affect gTLD expansion policy in this direction is also long passed. Without claims of offensiveness or community harm caused by any specific strings, the gTLD review process really will be unable to properly evaluate this objection.
And finally, there is something puzzling and inconsistent regarding the objection to monopolizing words at the top level of domains but not at lower levels. For instance, why is single ownership of the "book" TLD more objectionable than single ownership of "book.com"? Arguably, if domains such as "book.com" and "book.co.in" (etc) were not allowed to be privately owned and monopolized, and the domains could be used by multiple book-related destinations, there would be no need for the expansion happening now. Without previous objection to private ownership of common words at lower levels, there is less justification (and less credibility) to now object to private ownership at the top level.
Seth Reiss
I find the second point of IT for Change, India's submission to be compelling and well reasoned. I do not know whether this issue is properly within the RG's remit but I think At Large is the proper constituency within ICANN to move such concerns forward. I understand that this is an issue (generic words proposed by applicants who would not allow others to use the domain but instead run it privately) was previously raised and determined not to be within the RG's scope. I agree that it does not smoothly fit within the the scope of the Community Objections definition but I am not yet convinced that it could not be promoted by the RG as such. I would encourage further discussion of the point.
Evan Leibovitch
Hi Seth,
Let's be clear. There is nothing at all in the Amazon applications (the main target of the "private ownership" complaints) to indicate that Amazon "would not allow others to use the domain", just that it would retain ownership. Amazon has not, nor has it been asked to, provide detailed business plans or intentions for use.
We already have many examples in which hosting companies or consultants obtain domains on behalf of customers but retain ownership themselves. And it is quite easy to envision a TLD which "leases" subdomains under long-term contracts but retains ownership. In fact, such a scheme could greatly benefit end-users because it would simplify WHOIS-type consumer accountability issues while vastly reducing park pages, scam sites, defensive registrations and speculative domains. Amazon could have acquisition policies far more stringent than ICANN's own, while enabling legitimate short-term domains (for contests and product launches, for instance) amd offering a price that could be lower than is now typical.
Exactly how would such a TLD option be against the public interest?
It should be no surprise, then, that the biggest complaints against "private ownership TLDs" come from the domain industry, the speculators and middlemen who would be shut out of such a scheme.
Sure, Amazon could use its TLDs as massive filing systems (think "http://stephenking.horror.english.book") ... or it could be used to provide a public TLD with no park pages, no speculators and no scam sites. I personally look forward to seeing new models for the distribution of domains that innovate beyond the commodity model.
The larger issue of private ownership of common words is valid, but very different from the complaint above and long ago decided by ICANN in a quite irreversible manner. And IMO it is also applicable to second level domains.
Eduardo Diaz
I agree with Evan with his statement: “...the ability to affect gTLD expansion policy in this direction is also long passed.” It is my understanding the the comment is not directed to an specific new gTLD. It is similar - in scope but not content - to the comment generated by InternetNZ (https://community.icann.org/display/newgtldrg/.book+_OG).
Justine Chew
If we follow the guiding framework for the gTLD RG on comments, strictly speaking I fail to see how the comments by IT for Change, India could be said to be on Community Objection grounds simply because:-
(1) they have not specifically pointed to which community or communities are affected by the gTLDs that they have mentioned;
(2) even if they narrowed down their comments to one single gTLD, then it is also questionable if they are the right community to raise comments or objections to that gTLD.
While I agree with Evan on his point about there being no evidence that a successful gTLD applicant would not allow external usage of secondary gTLD although that presumption against such is not uncalled for since (1) it would imply that a successful gTLD applicant would become domain registrar for its gTLD and (2) there is no expressed obligation on the part of a successful gTLD applicant to do so at present (if I am not mistaken).
In the scheme of things as they stand, the question for me remain two-fold:-
(1) Is it within the scope of the gTLD RG to act on such a general (for want of a better description) comment? I think not; and
(2) Can the architecture of the entire gTLD framework be overhauled now? It seems to me given the feedback of some RG colleagues that the answer is NO, the time for that has long passed. If so, then is there anything ICANN can do at all to reverse or mitigate consequences which ALACs view as crucial? If yes, then great but I doubt that that is for RG to contemplate.
By all means, forward these policy concerns to the powers that be for their consideration.
Dev Anand Teelucksingh
Below is the gTLD RG decision regarding IT for Change, India's comments
Dear All,
The gTLD Review Group (gTLD RG ; https://community.icann.org/x/u7-bAQ)
received a comment from IT for Change, India on September 11 2012.
IT for Change, India's comment was not directed at a specific application or applicant but was posted to the At-Large new gTLD Applications Dashboard at https://community.icann.org/display/newgtldrg/multiple-strings-by-IT-for-change_OG for comment.
The comment by IT for Change, India is that allowing generic words as private TLDs (i.e with single registrant, with no requirement to make second level domain names available to the open market) is against the public interest.
Because such a concept is outside the scope of any particular applicant or application, the gTLD RG will not be submitting a comment for the ALAC for possible submission to ICANN's new gTLD comment forum
before the close of the Application Comment Period on September 26 2012.
However, given the concept raised regarding generic words becoming private TLDs 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 (new gTLD WG ; https://community.icann.org/x/8Yoi) for discussion and possible policy recommendations. We note that the issues referred to the new gTLD WG from past comments received by the gTLD RG (https://community.icann.org/display/newgtldrg/.book+_OG) have been
added to the new gTLD WG's agenda.
Kind Regards,
Dev Anand Teelucksingh
Chair, gTLD Review Group