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Name: Dirk Krischenowski
Date: 23 Jul 2025
Affiliation: dotBERLIN GmbH & Co. KG
Email: [email protected]
Original Public Comment: Final Proceeding for Proposed Language for the Draft Next Round Applicant Guidebook (AGB)
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.
No

If no, please explain

The expansion oft he namespace is based on ICANNs mission to „foster diversity, encourage competition, and enhance the utility of the DNS“. geoTLDs are a cornerstone of this mission as they provide local participation, trust, and identity for cities, regions, as well as for cultural and linguistic communities. Responseability for the consent or non-objection of the relevant government and for the necessity of a supporting document solely emerges from the geoTLD applicant and the relevant local government. Relevant governments in this context may be national institutions, city or regional governments or other even organizations. We fully consent ICANNs decision to outsource the verifcation of the support or non-objection letter to external experts for liability reasons instead of asking the GAC for confirmation. Similiar to a brand TLD application which requires a trademark eligibility verification, a geo TLD application requires a verification of the support or non-objection letter. It seems unreasonable that fees for a trademark database review costs USD 500,00 whereas a review of a support or non-objection letter shall cost USD 18,000 – 25,000.