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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.

Contenido disponible solo en los siguientes idiomas

  • English

Name: Registries Stakeholder Group (RySG)
Date: 7 Feb 2025
Email: [email protected]
Original Public Comment: Third Proceeding for Proposed Language for Draft Sections of Next Round AGB
1) Is the proposed Next Round Applicant Guidebook language for Application Comments (Topic 28: Role of Application Comment) consistent with the relevant SubPro Final Report recommendations?
Yes
2) Is the proposed Next Round Applicant Guidebook language for GAC Member Early Warnings (Topic 30: GAC Consensus Advice and GAC Early Warning) consistent with the relevant SubPro Final Report recommendations?
Yes
3) Is the proposed Next Round Applicant Guidebook language for GAC Advice (Topic 30: GAC Consensus Advice and GAC Early Warning) consistent with the relevant SubPro Final Report recommendations?
Yes
4) Is the proposed Next Round Applicant Guidebook language for Singular/Plural Notification (Topic 24: String Similarity Evaluations) consistent with the relevant SubPro Final Report recommendations?
Yes
5) Is the proposed Next Round Applicant Guidebook language for Objections (Topic 31: Objections and Topic 32: Limited Challenge/Appeal Mechanism) consistent with the relevant SubPro Final Report and IDN EPDP Phase 1 Final Report recommendations?
Yes
6) Is the proposed Next Round Applicant Guidebook language for ICANN Dispute Resolution Procedure (Topic 31: Objections and Topic 32: Limited Challenge/Appeal Mechanism) consistent with the relevant SubPro Final Report and IDN EPDP Phase 1 Final Report recommendations?
Yes

If no, please explain

The RySG notes that the ability to fully assess this draft section of the AGB is limited by the amount of information that needs to be provided by specific Dispute Resolution Providers. In later versions of the AGB, we encourage ICANN to provide as much detail as possible, in particular with respect to the costs associated with dispute resolution for each Provider, so that future applicants have sufficient information to make informed decisions.

7) Is the proposed Next Round Applicant Guidebook language for ICANN Objection Appeals Procedure (Topic 31: Objections and Topic 32: Limited Challenge/Appeal Mechanism) consistent with the relevant SubPro Final Report and IDN EPDP Phase 1 Final Report recommendations?
Yes

If no, please explain

It is very helpful that this section of the AGB clearly notes that there is a specific end of the appeals process. We believe this is a positive development for the next application round.

8) Is the proposed Next Round Applicant Guidebook language for New gTLD Program: Next Round Privacy Policy consistent with the relevant SubPro Final Report recommendations?
Yes

If no, please explain

The RySG suggests adjusting Section 12 of this section on Revisions to the Privacy Policy. If the Privacy Policy changes subsequent to the initiation of the application window, ICANN should proactively notify the data subjects whose data it has collected, rather than only post the revised Policy to a website or updated version of the AGB.

9) Is the proposed Next Round Applicant Guidebook language for Post-Contracting consistent with the relevant SubPro Final Report recommendations
Yes
10) Is the proposed Next Round Applicant Guidebook language for DNS Stability consistent with the relevant SubPro Final Report recommendations?
Yes

If no, please explain

The RySG suggests two modifications to improve this section of the AGB: first, in order to minimize confusion that could result in the event that the IDNA2008 RFCs are updated while the application window is open, the language referencing these RFCs should include an “as of” date, at least for the purposes of the 2026 application round. Second, this section of the AGB should provide more detail about how the results of a test could be challenged. As currently written, the section states that applicants will have the opportunity to challenge a test, but provides no information as to how that can be done.

11) Is the proposed Next Round Applicant Guidebook language for Security and Stability (Topic 26: Security and Stability) consistent with the relevant SubPro Final Report recommendations?
Yes

If no, please explain

While this draft section is consistent with RSSAC guidance, we note that as written, the text implies that the rate of delegation can change ONLY if ICANN determines that DNS service instabilities have occurred. We suggest revising this language to allow ICANN to adjust the delegation rate if it has sufficient reason to believe DNS service instabilities may potentially occur.

12) Is the proposed Next Round Applicant Guidebook language for Different TLD Types (Topic 4: Different TLD Types) consistent with the relevant SubPro Final Report recommendations and IDN EPDP Phase 1 Final Report recommendations?
No

If no, please explain

In this draft section, “Category 1 Safeguard TLDs” are defined extremely vaguely. The draft text does little to provide clarity for future new gTLD applicants as to whether their applied-for string might fall into this category and what additional information or safeguards they will need to provide as a result. It is also unclear who makes the determination that a string qualifies as a “Category 1 Safeguard TLD” and how that determination is made - future applicants cannot simply rely on past GAC actions or the examples cited in this section to understand how their own applications might be assessed. More transparency is needed here. Additionally, this section should also include information about whether an applicant may make changes to its application in order to not qualify as this type of TLD.

13) Is the proposed Next Round Applicant Guidebook language for Legal Compliance Check consistent with the relevant SubPro Final Report recommendations and IDN EPDP Phase 1 Final Report recommendations?
Yes
Do you have any additional or general comments?

The RySG appreciates the work that has gone into drafting these sections of the future AGB. For new gTLD applicants who are not experts in ICANN policy or steeped in the history and context that has resulted in the text of the AGB, transparency of the rules and predictability of the application, evaluation and subsequent processes is critical. We urge ICANN Org to keep this in mind as it continues drafting new sections of the AGB and refining these draft sections into their final versions.


While we recognize the efficiencies offered by publishing the draft AGB in segments and believe this approach to be sensible, the RySG also notes that it will be important for our stakeholder group as well as the rest of the ICANN Community to conduct a thorough review of the full draft AGB once it is ready. With that in mind, we request that ICANN Org provide a longer comment window (i.e., longer than 60 days) for review of the final draft AGB.