If no, please explain

Terminology of contention sets — - §1.2.2.1, §1.2.2.2 and §1.2.2.4 use the terms “preliminary contention sets” and “final contention sets”. - §1.2.6 introduces the term ”updated list of contention sets” (after string evaluation is completed). - §1.2.7 refers twice to the term “initial list of contention sets”, which can refer to either of the three previously introduced terms. We suggest ICANN to use consistent language throughout the AGB. Minor issues — - §1.2.4 expects the String Evaluation to last for 180 days; the flowchart in §1.3 shows 168 days. - §1.3: the flowchart includes a white block ‘Process’, which is overlapping the yellow area of ‘Contention Resolution’. A bit to the left, there is a lonely word ‘Process’ in the chart.

If no, please explain

Finalization of ASP discounts — §2.3.1.2 reads: “ICANN will inform qualified ASP applicants of the final discounted fee before the closing of the gTLD application submission period.” The currently proposed discounted fees range from $34.500-$56.750, which is a difference of more than 64%. ASP-eligible applicants may want to postpone their final decision until full price details are known. This contradicts section 2.1.1 that advises not to wait until the end of the period, and might be a challenge given the short invoice due date of 7 days after closing the application submission period in section 2.3.1. We suggest publishing the final fees 14 or more days before the end of the submission period. Conditional fees — §2.3.2, table 2-2 defines a conditional fee for Geographic Names Review that is estimated between $18.000-$25.000. The clear definition of a ‘Geographic Name’ (§6.5.2), together with the required letter of support or non-objection and the involvement of the GAC within ICANN, provides a all conditions for a smooth evaluation. Therefore, it is unclear why the estimated costs are (in our opinion) so excessive. An additional fee of this amount may form a serious obstacle for potential applicants, because they are targeting relatively small communities and in many cases public money is involved. We urge ICANN to reconsider this fee, preferably waiving it completely, given that the applicant already bears most of the burden of evidence. Refunds — According to §2.3.3.1, the second refund window runs “until the start of the Application and Applicant Evaluation”. The AGB does not make clear how the applicant is made aware of this start date. We suggest that ICANN adds to the AGB that it will inform the applicant about this start date, and when it will do so.

If no, please explain

Blocked names — In §6.2.1, the AGB lists 5 categories of “blocked names”. All categories are more or less clearly defined, except the “Technical Standards” category. As Blocked Names Identification is an automated pre-submission process (see §1.2.1.8.1), there will be an exhaustive list available also for those “Technical Standards”. We suggest ICANN includes (a reference to) this list in the AGB. Separable country names list — §6.5.1 refers twice to the “Separable Country Names List” in Appendix 2.2. Although we understand that ICANN bases this list on the ISO-3166 standard, we find that this standard does not always resemble the correct situation. For example, ISO-3166 contains codes for places that are no countries (anymore), but municipalities. By including those municipalities in the Separable Country Names List, those municipalities cannot apply for their own municipality names, even if local government is supporting such an application. We request ICANN to review the decision to mark all names in Appendix 2.2 as ‘blocked names’ Geographic Names Review — §6.5.3.2, third paragraph (application determined as “not a Geographic Name”) states that in this case “no additional steps” are required. To our understanding, this also means that no conditional fees (at least those for geographic names review) are required anymore. For clarity, we suggest ICANN to explicitly add such a statement to this third paragraph. Minor issues — - §6.8.3: the table caption is formatted as header, and overlaps with the ‘real’ header for §6.8.3. - §6.10.1, p215 3rd bullet and same page list item #6: footnotes 222+223 and 226+227 are visually glued together; we suggest to separate them with a comma for better readability.

If no, please explain

Two minor remarks: - Question 58 (phone number of users) is marked ‘public posting: yes’, which is probably incorrect. - Question 120, 129, 135 and 141 (generic strings): The question solely refers to the definition of “generic string” in section 3(d) of specification 11 of the base RA. In our interpretation, this means that not any generic string (e.g. “.shop”) would be allowed to proceed. We believe the intention of the question is to cover this full section 3(d) and not only the definition. We suggest to refer back to §2.1.7: “This applied-for string is not a Closed Generic or Exclusive Generic String as specified in section 2.1.7 Closed Generics/Exclusive Generic Strings.”