Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Christopher Niemi
Date: 23 Jul 2025
Affiliation: Markmonitor
1) Is the language in draft Module 1: The Applicant Journey consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

The language as a whole is consistent with the Board-approved recommendations and is consistent across the AGB, but the current wording in Section 1.2.9 -- “If an auction winner is ineligible to execute a Base RA with ICANN, ICANN may, at its discretion, offer the auction runner-up, if any, the opportunity to proceed with its application.” -- may be confusing for applicants. That is, the next sentence after the above referenced sentence provides a link to the “ICANN New gTLD Auction” section; it may be beneficial to also add a link in this sentence to Section 1.2.15 Contracting or to another section that could better speak to reasons for eligibility or ineligibility to sign a Base RA. When an applicant has clear access to eligibility requirements ahead of time, they can prepare appropriately for Contracting and other parts of the Applicant Journey and avoid ineligibility to sign a RA and potentially losing an auction. The current wording could be an obstacle to that preparation so clarifying it is warranted.

2) Is the language in draft Module 2: Application Submission consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
3) Is the language in draft Module 3: Community Input, Objections, and Appeals consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
4) Is the language in draft Module 4: Contention Set Resolution consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
5) Is the language in draft Module 5: Applicant Evaluation Procedures consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
6) Is the language in draft Module 6: String and Application Evaluation Procedures consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

The language as a whole is consistent with the Board-approved recommendations and is consistent across the AGB, but section 6.3.3.2 says “Additionally, mission and purpose statements must demonstrate non-generic usage.” Per Appendix 1, Question Set 13: Brand TLD and Code of Conduct Exemptions (questions 190-195), there is no mention of needing to provide “mission and purpose statements” as part of any of the answers to these questions. Please clarify the wording in 6.3.3.2 to state whether submission of these “mission and purpose statements” is necessary to meet the requirements of the Brand TLD Exemption process as that could thereby affect an application negatively if not provided. Alternately, please clarify if providing the “ mission and purpose statements” is an optional part of the process.

7) Is the language in draft Module 7: General Information consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
8) Is the language in draft Appendix 1: Application Questions consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

The Application Questions as a whole are consistent with the Board-approved recommendations and are consistent across the AGB, but in the current format of how the questions are communicated, it is very confusing exactly what questions need to be answered by which of the four Profile types. Please insert a list, chart, or workflow into Appendix 1 that states which question number/set must be completed by which Profile type, for all four Profile types. This will improve clarity and minimize confusion for applicants as they prepare applications.

9) Is the language in draft Appendix 2: Materials related to Geographic Names consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
10) Is the language in draft Appendix 3: Objection and Appeal Materials consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
11) Is the language in draft Appendix 5: Templates for Standard Financial Profile consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
12) Is the language in draft Appendix 6: Predictability Framework consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
13) Is the language in draft Appendix 7: Conflict of Interest Process for Service Providers consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
14) Is the language in draft Appendix 8: Code of Conduct and Conflict of Interest Guidelines for Service Providers consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
15) Is the language in draft Appendix 9: New gTLD Program: Next Round Privacy Policy consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
16) Is the language in draft Appendix 10: Terms and Conditions consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes