For Your Feedback on “Expressions of Interest” — ICANN Asks
ICANN asks for feedback on Expressions of Interest for fresh TLDs.
As I’ve noted ahead of, ICANN is exploring accepting “expressions of interest” for fresh top level domain names. This would allow applicants to put their hat in the ring for fresh TLDs and give the internet community an idea of the scale and complexity we’re dealing with.
In principle, it sounds like a good idea. The devil will be in the details.
ICANN just opened up a comment period to provide guidance on the “Expressions of Interest” idea. The deadline to submit comments that will be considered by the board at its December meeting is November 27.
Here is the feedback I just submitted:
I like the idea of “Expressions of Interest” for fresh top level domain names. If properly implemented, it will give us an idea of the scale and complexity we’re dealing with for fresh TLDs. It will also help us understand particular string contention issues that may not have been anticipated in the Draft Applicant Guidebook (DAG), or at least provide specific examples to debate. I wish to comment on a few aspects of the idea:
1. There must be an incentive for firms to participate. My preferred incentive is to require firms to participate in the EOI if they want to apply for the TLD. Otherwise, the EOI will not provide an accurate estimate of interest.
2. There must be a penalty for firms that don’t follow through with applying for the TLD that they submit an EOI for. My preferred penalty is to require a steep, non-refundable fee to submit an EOI. I understand that some firms may be wary to pay a significant amount when there is no guarantee that fresh TLDs will go forward. That’s a risk they might just have to take.
The fee ought to be per TLD applied for; otherwise one applicant may file for a number of TLDs to “scare off” competition.
3. ICANN ought to understand that the level of applications under EOI does not indicate economic demand for fresh TLDs from registrants. It only indicates a level of demand from entrepreneurs wishing to release fresh TLDs.
A number of people have called for the economic studies on fresh TLDs to be carried out. But let’s be honest, we can look at previous fresh TLD rounds to see the level of demand for fresh TLDs. It’s relatively low. I’d rather ICANN not waste any more money paying an economics professor to write “whitewash” notes on the economic demand and benefits for fresh TLDs.
4. With regards to the question on if a firm can get a refund if the DAG changes, this is a tough question. There must be some level of significant change to allow a firm to back out, and it must be clearly defined. Otherwise there will be a loophole which will negate the entire benefit of the EOI. Again, this is a risk firms will just have to take. Everyone entering the ICANN process for fresh TLDs knew there as risk it would either be significantly delayed or may never happen, so it’s just part of the risk equation.
