We have long argued that ICANN should consider categories for new gTLDs because different categories will have markedly different benefits and impacts for consumers.

It is difficult to represent the complexities of the world in any system and the flat, first come first served single level approach ICANN is proposing is actually more cumbersome, more restrictive, more expensive and less equitable than the very successful existing system it is seeking to extend. Quite simply what ICANN is proposing even at this late stage and after years of planning is not a sensible approach for the introduction of new gTLDs.

More cumbersome

At the moment it’s $10 p.a. + hosting, and with a computer, an internet connection and a credit card you can be up and running within a few minutes.

Under ICANN’s proposed new system you have to wait until ICANN decides to grant an application window. You then have a couple of months or so to explain why your brand should be granted a top level domain, hope your .brand isn’t too generic so there isn’t an auction, and then wait another half a year or so to be delegated.

More restrictive

The rules framing new gTLDs are stricter than those for second and third level domains. For example: No hyphen (dash) signs. No single letter gTLDs. No two letter gTLDs—two letters are reserved for country code TLDs (ccTLDs).

.ibm .dell no problem but what about Hewlett Packard? .hp is not possible.

Proctor and Gamble won’t be able to have .pg but their situation is more complex because their brands are built around different products and $185,000 + $25,000 p.a. just doesn’t scale well….. .ace, .ariel, .bold, .bounce, .bounty, .cascade, .charmin, .cheer, .comet, .... and that’s just the a, b & c’s of brands for the household care division!

A lot of brands are constructed from associations with places and generic words which will result in inevitable naming collisions for some brand holders and being a flat single level system only one entity can exist at the top level (to the right of the dot) ever.

Who gets .merck? The U.S. drug company? Or the German drug company with the same name? This is a step backwards; in the existing hierarchical system merck.de and merck.com can equitably coexist.

.cat that’s already taken and what about .lincoln .amazon .mac? Place or brand or a first come first served mix perhaps? Where’s the consistency?

Plus in a flat single level system to the right of the dot, future expansion is not possible.

More expensive

New gTLDs will in the main be an increase in the cost of doing business for most real world businesses. Why? Because they are an additive measure which will bring little if any innovation to the domain name system.

.brands are a classic example where you can pay ICANN $185,000 + $25,000 p.a. in addition to $10. p.a. for a .com. Now that may help with a short term branding advantage, but it means if a major player moves to the right of the dot in any vertical then all the other companies will also have to move to simply enjoy the same level of implicit DNS branding.

To put those costs in context, a single company like Proctor and Gamble with over 80 brands will need to spend over $15,000,000 if they wish to apply for all their brands as new gTLDs and pay ICANN a further $2,000,000 every year going forward compared with the existing system cost of $800 p.a.

Once the other companies move much of the DNS branding advantage is lost but the year on year costs remain. Great for ICANN and their contracted parties, but ultimately that cost has to be borne by consumers.

Less equitable

.com isn’t sold or advertised by VeriSign. It is sold and branded implicitly by virtually every major corporation using it day in day out across all their communications. It’s that simple. The success of the internet is because it delivers efficiency to the market place. It enables anyone to reach an unfathomable number of people simply by buying a domain name.

.brands will destroy the ability to compete on a level playing field. At the moment to launch some software designed to compete with major brands such as Microsoft or Sun costs $10 + hosting a year then it’s down to skill and innovation.

Medium sized players will have to consider whether it’s worth spending $185,000 + $25,000 per year with ICANN to enjoy the same level of implicit DNS branding and enter ICANN’s .brand super league. For start ups and smaller players the cost of admission to this implicit DNS branding advantage is likely to prove prohibitive.

The level playing field of the internet will be destroyed.