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Neustar has sent the below letter to ICANN. Neustar sent the letter to urge caution to ICANN before launching the batching process to promote competition and choice for consumers in a fair and balanced manner.
Neustar has long been an advocate for the introduction of new generic top level domains. Given the long and sometimes arduous road the ICANN community has traveled to get to this point in the process, we are understandably anxious to avoid unnecessary delay in the launch of new gTLDS. Ironically, perhaps, it is concern about further delay that motivates Neustar to join those who have called upon ICANN to pause briefly before launching the Digital Archery “batching” process.
Batched consideration of new gTLD applications may, in the end, prove to be less undesirable than other approaches, but even its strongest proponents acknowledge its limitations. And, while assumptions and predictions about the number and variety of new gTLD applications necessarily drove both the need for and the design of the Digital Archery solution, the application process has closed. A modest delay would permit both ICANN and the community of affected stakeholders to consider the validity of those assumptions in light of actual applications. Others have suggested alternatives to the batching process itself, which also may now be evaluated in light of the applications received. Informed reflection by the community could result in greater efficiencies and fewer disputes down the road. On the other hand, launching the Digital Archery process prior to publication of the list of applications is going to create winners and losers that will unnecessarily complicate, and perhaps prevent, thoughtful adjustments to the approach.
We believe that there is ample time between now and ICANN’s meeting in Prague to analyze the facts and to determine a course of action based on informed community input. Accordingly, Neustar urges a brief pause to review the need for “batched” consideration of new gTLD applications and, if such batching is indeed necessary, to fine-tune the program in light of actual applications.
J. Beckwith Burr
Deputy General Counsel & Chief Privacy Officer
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