Dotzon appreciates the opportunity to comment on this issue. We recognize and thank ICANN for their work on a tool and similarity data for calculation of the potential similarity for the applied-for strings (and their variant strings) for pre-screening. This is an important tool for the SSE Panel in conducting the subsequent independent manual evaluation. The result of this evaluation will prevent user confusion and loss of confidence in the DNS resulting from the delegation of similar strings.

Transparency, predictability, and consistency are fundamental principles that the ICANN community has already agreed upon during its deliberations in SubPro. We strongly recommend that these principles are fully implemented throughout the application process, particularly in relation to tools that directly impact applicant outcomes.

Therefore, we advocate that ICANN provide public access to the SSE Tool and its data foundation, or at minimum make it testable. For applicants, the ability to independently verify potential similarity issues before filing is critical for effective risk management and strategic decision-making. ICANN should also bear in mind that approved ASP applicants should be supported in the best way possible and one part of this support is access to the SSE Tool.