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Name: Bill Doshier
Date: 2 Apr 2025
Affiliation: dotStrategy, Co., The .buzz Registry
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 successful launch of the .buzz top-level domain by dotStrategy, Co. during the 2012 round I believe stands as a compelling example of how single operator ventures can thrive under ICANN’s New gTLD Program when equitable conditions are in place. The original 2012, 80% refund policy for early withdrawals significantly lowered the financial risk to entry, encouraging many innovative, mission-driven smaller scale applicants to take on the risks of launching a new domain. dotStrategy’s success with .buzz confirms ICANN’s model can support wide participation when risk is reasonably managed. If the aim for round two is to reduce participation from independent entrepreneurial applicants, then lowering the early withdrawal refund to 65% is a remarkably effective - if troubling - first step, and one that may well compel the next .buzz to step aside before ever applying. The current proposal to reduce early withdrawal refunds to 65% undermines the inclusive spirit of the program. Applicants now face a significantly higher application fee, yet are being offered a substantially weaker safety net. An applicant may forfeit nearly $80,000 within weeks, even with minimal engagement from ICANN, making the process disproportionately risky for single - or start up - applicants. The SubPro Final Report explicitly calls for a predictable and fair refund structure, particularly in uncontrollable scenarios such as name collision risks. Paired with mandatory Auctions of Last Resort—which inherently favor well-funded entities—the reduced refund amplifies systemic inequity and will deter many of the very applicants ICANN claims to support. Restoring the 80% refund is not just about fairness—it’s about ensuring that the next .buzz has a real chance to emerge in a policy environment that values inclusion, innovation, and opportunity.

Other Comments

I have very few additional concerns with the next round AGB. Certainly none which are noteworthy. I do feel strongly the currently proposed refund policy deserves a solid rethink.