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.

Name: Lawrence OlaWale-Roberts
Date: 2 Apr 2024
Affiliation: Business Constituency
1. Do you believe that Section 1 (“Introduction”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
2. Do you believe that Section 2 (“Overview”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
3. Do you believe that Section 3 (“Applicant Support Program Timeline”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes, but with the following suggested clarification(s)

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

It is heartwarming to note that Applicants who apply early would not need to wait till the end of the process to be informed if they qualify for support or not. However, the import of this statement is not clear and should be worded better for clarity. Also, (based on wordings in page 9) if applicants are going to receive an evaluation result within 12-16 weeks of applying and assuming this is done in Q4 of 2024, it is not totally clear how applicants applying in the weeks ending the application process impacts those who have qualified. As the Applicant Support window opens months ahead of the New gTLD application round and recipients for an award are required to be informed of the level of support to be granted them or not, it is not clear if there would be a requirement to disclose such gTLD or brand names support is being sort for. It is therefore presumed that such confidential details would not be required for disclosure in the bid to seeking Applicant support. As such the guidebook not mentioning any restrictions to the kinds of TLD to be supported, means it is open to every form of support including city TLD’s. With the start of applications for Applicant Support opening in Q4 of 2024 until Q4 of 2025, this does not leave much room for the required breath of outreach and engagement needed to sell the program across the global south where this support is most needed. It is my hope that whilst all necessary steps are put in place to kickoff outreach efforts, at least six months into the application window closing, credible outreach should still be in full swing across the global south.

4. Do you believe that Section 4 (“Reduction of New gTLD Program Application and Evaluation Fees”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes, but with the following suggested clarification(s)

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

Since it is anticipated that the next round would closely follow the criteria laid out in the 2012 round, it would be expected that the rebate in cost of the fee reduction for Qualified ASP applicants granted in the coming round be at the level of the 2012 round or better due to inflation. The global south aspirants will benefit better from a fee reduction of at least 70% to 85%.

5. Do you believe that Section 5 (“Applicant Eligibility and Evaluation Criteria”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes, but with the following suggested clarification(s)

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

Happy to see that eligibility of applicants includes small businesses from developing regions. However medium and large businesses from developing regions may very well require applicant support to apply for a gTLD, whilst their financial chest would help to keep such registry services afloat and running as a viable concern in the years ahead. Small businesses from the global north that may require Applicant support for their brands and as a gTLD should also be encouraged to apply. Language and text in the applicant support guidebook seems to imply that every applicant will only be allowed to submit a single application and that a consulting firm can only submit one on behalf of a single entity throughout the process. For example text in the guidebook states that “Applicants are not allowed to re-apply,” hence this suggests that only one application is allowed per applicant. Hence, what path is available for an applicant seeking to submit an application for an IDN variant of the same string being applied for, or an applicant desiring to submit two or more independent applications in the same round? where more than one application is permitted would there be a means of prioritizing the choice of what would be awarded support.

6. Do you believe that Section 6 (“Applicant Support Program Application Process”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
7. Do you believe that Section 7 (“ASP Application Evaluation”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
Other Comments

Successful Applicants according to the GGP recommendations are to have their progress tracked after a period of 3 years. The guidebook should explicitly mention signing up for this review as a criteria for accessing applicant support. 


ICANN should explore ways to transpose the guidebook into simpler terms should be explored with its translation into diffrent languages adopted.


Summary of Submission

I appreciate the body of work that has resulted into the production of this guidebook. I am happy to see that eligibility of applicants includes small businesses from developing regions. However medium and large businesses from developing regions may very well require applicant support to apply for a gTLD, whilst their financial chest would help to keep such registry services afloat and running as a viable concern in the years ahead. Small businesses from the global north that may require Applicant support for their brands and as a gTLD should also be encouraged to apply. 

Successful Applicants according to the GGP recommendations are to have their progress tracked after a period of 3 years. The guidebook should explicitly mention signing up for this review as a criterion for accessing applicant support. 

Language and text in the applicant support guidebook seems to imply that every applicant will only be allowed to submit a single application and that a consulting firm can only submit one on behalf of a single entity throughout the process. For example, text in the guidebook states that “Applicants are not allowed to re-apply,” hence this suggests that only one application is allowed per applicant.

Hence, what path is available for an applicant seeking to submit an application for an IDN variant of the same string being applied for, or an applicant desiring to submit two or more independent applications in the same round? where more than one application is permitted would there be a means of prioritizing the choice of what would be awarded support.