If no, please explain

Based on the personal experience I lived when I was the project leader of a community application in the previous gTLD´s round, that succeeded after three years of contentions with non community based applicants, the answer is “no” because of the following reasons 1) One point that is not considered enough and that risks to create a lot of future discrimination, is the case of names shared by more than one community. Because of the very large interpretation given to the definition of “community”, for a name such as “Dervish”, could apply either the club of the videogamers passionate of the videogame called “Raid shadow legends”.(where one of the main champion is called “dervish”) and the sufi dancers defined with the same term. According to the current formulation of the Evaluation criteria, there is no doubt who the winner will be. The videogamers are structured in clubs (organization criteria), existing in multiple countries (established presence criteria), since several years (longevity criteria), they organize tournaments recognized by international federations (engagement criteria). While the real dervishes (from which the videogame personage took the name) of the Mevlevi Order would be in a situation where their comments, where were they to organize across many countries, cultures and languages, , they could easily be ignored under the Community Endorsement scoring because the current text states: “While these (letters and comments “noting opposition”) “will be assessed, they do not automatically influence the Opposition score.” But the policy adopted by the GNSO gives them great value to comments of concern submitted by larger and older communities, and they should not be ignored by the Panel, but carefully considered. Further, under current evaluation criteria, the “Longevity” of Mevlevi order could not be recognized by the experts evaluating the videogamers’ CPE request, despite the fact that such movement started in the XIII century AC. 2) Coming back to the fundamental principles taken in account in the previous versions of the guidelines 2025, we need to Identify experts that have a real knowledge and understand of all kinds of communities existing around the world. UNESCO, for instance has an expertise in indigenous languages and tribes; UN since its inception deal with these kinds of communities and other similar institutions exist around the world. UNESCO should provide CPE Panelists. a) Moreover, there is an expertise already within the ICANN community. After all, many TLDs of this kind were recognized in 2012 (many geonames such as DOT.Berlin, DOT.gal, DOT.swiss, DOT.scot , and also non geo-communities such as DOT.catholic, DOT. Shia, DOT.ieee, not to mention DOT.radio). Not to mention the precursor of all: DOT.Cat. We can draw CPE Experts from these successful communities. b) Further, the final AGB must give back to these experts more discretionally power in the choices. The currently wording saying that Fact-checking has to be limited solely to “information provided by the applicant”, and that “organization” criteria has to be measured only “according to the size of the identified community of the applicant” means that videogamers application for “Dervish” could be approved instantly, despite the fact that a community with the same-name exists since 8 centuries. c) Giving to the CPE expert, in case of an application using a name common to more communities, the possibility to approach the other more relevant community/ies and check if they are aware of the application and if they have objections (or not) to give their name to somebody else is reasonable. Let´s remember what happened in the first round when DOT.Patagonia´s application submitted by a fashion brand was withdrawn because of the complaints from some concerned governments. 3) Finally, in cases where the applicant is not trying to take the name of a larger, better-known community, then the criteria identified for the recognition of a community are too narrow and risk excluding the smaller, poorer and less organized communities, that -in principle, according to the spirit of the CPE, would have to be the ones that ICANN want to protect more. The criteria as they currently described will give full points to a well established economic community (such as .tennis), but risk giving a very low score to other more controversial communities, such as gays, just to mention one of the biggest difficulties of the first gTLD´s round or to DOT.rohingya. a) In both cases -for communities that are controversial and that are even outlaws in some countries- how could be possible to demonstrate the organization criteria (how they could organizes themselves in countries where such organizations are considered criminal activities?) and equally the “Established presence” and the “Longevity” or even perhaps the “Engagement”? b) In synthesis, while the current criteria are valuable to identify and easily recognize existing structured and economically solid communities (as it was the case in the first round for DOT.bank, DOT.insurance, DOT.pharmacy, DOT.radio), they are not suitable to identify, recognize and compare other communities, even more important, but less organized, poorly financed and eventually divided among themselves. More than happy to help in finding the appropriate wording for these concepts in the new Guidelines NB: all words between brackets are excerpted from Section 4.4 “Community Priority Evaluation” or Section 4.4.7 “Community Priority Evaluation Criteria” . Signed: Giacomo Mazzone Project leader for the DOT.radio application on behalf of the EBU/WBU at the time of the first gTLD´s round, now acting as consultant and expert in Internet governance matters.

If no, please explain