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The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.

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FIRST DRAFT SUBMITTED

The At-Large Advisory Committee (ALAC) would like to reiterate its Full support to the concept of supporting the domain name industry (DNI) in underserved regions, which was expressed in 2014.

The ALAC also mentioned that as the DNI programs evolve, the following principles should be adhered to:

• Registrant and user rights and expectations must not be lowered in order to increase DNI penetration
• Education at all levels is a key to increasing demand and local suppliers
• The demands placed on registrars should be reasonable based on local cost-of-living and related financial constraints
• The insurance required for registrars is a real concern for the underserved regions (e.g. cost, convertibility of the local currency)
• The second round of the new gTLD program should give preference, if not exclusivity, to applicants from underserved regions, with the adequate outreach program that ensure a better understanding of the program, its benefits (e.g. economic, cultural, linguistic, etc.) and all the requirements for an application, as well as a technical and Legal Support.

Answering the 5 questions of the current public comment, the ALAC thinks that:

1. Even if things have evolved, there is still need to secure the registrants rights through the CGL insurance or any other mechanism.
2. A permanent fund reserved by ICANN for the coverage of any harm that the registrants might incur. This fund might be fed by the registrars on the basis of their transactions volume
3. In case the CGL requirement is maintained, the $500,000 limit should be lowered  to an amount that the registrar can demonstrate that it would still provide for reasonable compensation in the event of a covered loss
4. If ICANN decides on the elimination of the CGL requirement, it should be applied to the whole registrars. The insurance should be replaced by another mechanism to protect the registrants and users rights

The ALAC emphasizes that the CGL requirement is not the only barrier for the underserved regions, but it is one of the most important.

Its elimination could be the best way to support the underserved regions to participate in the domain name industry. The registrant rights should be secured by another mechanism such as a fund fed by the registrars according to their transaction volume and reserved by ICANN. The underserved regions’ registrars could be exempted from paying their part in the so-called fun first draft submitted will be placed here before the call for comments begins.