Will new gTLDs just be more of the same, or will they bring real diversity and innovation to the Internet’s namespace? For Hong Kong based Stable Tone, applicant for two Chinese character IDN TLDs (?? or “Dot WORLD” and ?? or “Dot HEALTHY”), it’s the smaller applicants that give the new gTLD program its soul.

Ahead of ICANN’s 48th international meeting happening in Argentina next week (from November 15), Stable Tone’s CEO Jason Du has commissioned a position paper on the plight of smaller applicants as they face the complexities of ICANN’s program.

“If politicians only listen to representatives of big business, then the laws they work on will probably not be well suited to the smaller entrepreneurs,” the paper says in its introduction. “As it works to launch the new gTLD program successfully, ICANN faces the same challenges of not only listening to the views of the people who are loudest or have the resources to come to ICANN meetings in person.”

Using practical examples of recent small applicant difficulties (such as DotGreen Community Inc.‘s decision to withdraw its application for Dot GREEN), the 14-page paper is an impassioned plea for smaller applicants to be looked after in the new gTLD program. “Because of their need to leverage their investments through economies of (large) scale, the Portfolio Applicants in the new gTLD market are akin to large department stores offering “lowest common denominator” products designed for mass production,” Stable Tone argues in the paper. “In comparison, Small-Lot applicants are like boutique retailers. They cannot compete on price or volume alone, but instead offer more specialised services for more targeted communities.”

Beyond stating the problem, Stable Tone uses the paper to suggest solutions… and to offer a definition for smaller applicants as entities which, once the dust settles on the first round of new gTLD applications, end up with a maximum of 5 TLDs under management.

Amongst Stable Tone’s suggestions are the implementation by ICANN of an exception mechanism to better shield smaller applicants from the effects of delays in change requests, an easing of the 100-name limit for registry use in such launch scenarios as “pioneer” programs for smaller applicants and in the wake of ICANN’s release of its tentative auction rules, recognition that as currently planned, the last-resort auction process is probably not well suited to smaller applicants.

Du has emailed the paper to both ICANN Board Chair Steve Crocker and New gTLD Program Committee Chair Cherine Chalaby. “Mr Chalaby gave us an answer straight away,” Du told me in a Skype interview. “He wrote back saying: “On behalf of the New gTLD Program Committee (NGPC), I acknowledge receipt of your letter. Many thanks for the thoughts and ideas put forward by Stable Tone Limited relating to smaller applicant / registry. Your letter will be handled as appropriate by the new ICANN Generic Domains Division which deals with all matters relating to Generic Domains.”

Another topic of community discussion for the Buenos Aires meeting?