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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.

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Name: Matt Serlin
Date: 23 Jul 2025
Affiliation: Pitch.law
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

While we generally are in agreement with the contents of this section, we do not see any mention of electronic (API) access to TAMS. We understand that application submission will not be allowed until the application window opens, but to assist providers who are working with applicants in the lead up to the application submission window opening, allowing for API access to TAMS would streamline the process and allow for electronic submission through secured means while also allowing applicants to accurately prepare their applications ahead of time.

8) Is the language in draft Appendix 1: Application Questions 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

While we applaud the inclusion of Brand TLD specific designations to make the process more streamlined for companies choosing to apply for a Brand TLD, we have a number of points which we feel need further clarification and/or changes. Question 175 asks applicants if, "people will see a domain name as more trustworthy because it is registered in your TLD?" One of the main motivations for a company to apply for a Brand TLD is for increased trust in any domain names registered in the Brand TLD, so the logical answer would be yes; however, doing so triggers inclusion of Safeguards 1-3 which don't seem to fit with the general designation of a Brand TLD. Question 213 indicates, "annual reports are not acceptable" but often times annual reports contain audited financial statements for publicly traded companies, so why would those not be acceptable? Several questions under the standard profile (specifically 224, 225, 227, 228, 229 and 230) ask the applicant to complete the most likely scenario projections plan, provide projected revenue and complete the financial risk assessment which do not seem to align with those who will be applying for Brand TLDs. While we appreciate the need for all applicants to demonstrate a financial commitment to operate their applied-for gTLD, we would encourage there to be a different path for Brand TLDs as those registry operators will not be selling domains to the general public and very well may operate at a loss as there would be no direct revenue being generated by the registry itself.