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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: Marianne Georgelin
Date: 1 Apr 2025
Affiliation: Afnic
Email: [email protected]
Original Public Comment: Fourth Proceeding for Proposed Language for Draft Sections of Next Round AGB
1) Is the proposed Next Round Applicant Guidebook language for Material Impact (related to Topic 2: Predictability) consistent with the relevant SubPro Final Report recommendations?
Yes
2) Is the proposed Next Round Applicant Guidebook language for Registry Voluntary Commitments / Public Interest Commitments (RVCs/PICs) (Topic 9: Registry Voluntary Commitments / Public Interest Commitments) consistent with the relevant SubPro Final Report recommendations?
Yes
3) Is the proposed Next Round Applicant Guidebook language related to Topic 5: Application Submission Limits, found in the draft AGB section entitled “Applicant Journey” consistent with the relevant SubPro Final Report recommendations?
Yes
4) Is the proposed Next Round Applicant Guidebook language related to Topic 16: Application Submission Period, found in the draft AGB section entitled “Applicant Journey”, consistent with the relevant SubPro Final Report and recommendations?
Yes
5) Is the proposed Next Round Applicant Guidebook language for Application Questions consistent with the relevant SubPro Final Report recommendations?
Yes
6) Is the proposed Next Round Applicant Guidebook language for Application Fees (Topic 15: Application Fees) consistent with the relevant SubPro Final Report recommendations?
No

If no, please explain

The current refund process described in the Next Round Applicant Guidebook proposes a 65% refund on applicant fees in the event of early withdrawal (compared with 80% in 2012). This lower refund is not clearly justified, especially considering the minimal processing of applications at the start of the pre-evaluation process (administrative checks only). The impact on applicants is significant. They stand to lose up to $80,000 between the initial payment and the first refund period, without any particular benefit, which is particularly problematic for small applicants and those in the Applicant Support Program. The application fee refund schedule should be structured more equitably particularly for unsuccessful applicants or those who withdraw their applications due to special circumstances. The SubPro final report stresses the need for a fair and predictable reimbursement structure. We therefore recommend that the repayment percentage for early withdrawals be increased to reduce financial risk and encourage diversified participation.

7) Is the proposed Next Round Applicant Guidebook language for Terms and Conditions (Topic 18: Terms & Conditions) consistent with the relevant SubPro Final Report recommendations?
Yes
8) Is the proposed Next Round Applicant Guidebook language for Order of Application Processing and the Prioritization Draw (related to Topic 19: Application Queuing) consistent with the relevant SubPro Final Report recommendations?
Yes
9) Is the proposed Next Round Applicant Guidebook language for Application Change Requests (Topic 20: Application Change Requests) consistent with the relevant SubPro Final Report recommendations?
Yes
10) Is the proposed Next Round Applicant Guidebook language for Financial & Operational Evaluation (Topic 27: Applicant Reviews: Technical/Operational, Financial and Registry Services) consistent with the relevant SubPro Final Report recommendations?
Yes
11) Is the proposed Next Round Applicant Guidebook language for Registry Service Provider Selection (related to Topic 27: Applicant Reviews: Technical/Operational, Financial and Registry Services) consistent with the relevant SubPro Final Report recommendations?
Yes
12) Is the proposed Next Round Applicant Guidebook language for Name Collision (Topic 29: Name Collision) consistent with the relevant SubPro Final Report recommendations recommendations?
Yes
13) Is the proposed Next Round Applicant Guidebook language for Community Priority Evaluation (CPE) (Topic 34: Community Applications) consistent with the relevant SubPro Final Report recommendations recommendations?
Yes
14) Is the proposed Next Round Applicant Guidebook language for Contention Set Resolution (related to Topic 35: Auctions: Mechanisms of Last Resort / Private Resolution of Contention Sets) consistent with the relevant SubPro Final Report recommendations?
Yes
15) Is the proposed Next Round Applicant Guidebook language for Code of Conduct Exemption Evaluation (Specification 9) consistent with the relevant SubPro Final Report recommendations?
Yes
16) Is the proposed Next Round Applicant Guidebook language for Brand Eligibility Evaluation (Specification 13) consistent with the relevant SubPro Final Report recommendations?
Yes