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"Do's and Don'ts": Commenting on New gTLD Applications

Statton Hammock

Like most new gTLD watchers, I have read with interest the public comments being posted regarding the new gTLD applications and, unfortunately, I have been largely disappointed with the substance of most of them. Too many of the earliest comments express concern over the possibility of having more adult-related extensions. Okay, we hear you (and so do the ICANN evaluators) so, please, no need to post more comments objecting to these strings. Also, with all due respect to the supporters of Dadotart's application, I appreciate the display of loyalty to this particular applicant but if I have to read another comment from an "impassioned supporter" of the .ART application, I will bang my head on my desk. And, finally, to Ms. Holme who filed the same identical comment to hundreds of application applications (I confess that I didn't actually count them all) concerning the lack of rights protection mechanisms, I can only say that I am impressed by the diligence you displayed in clicking the "submit comment" button that many times. (Would you also please "re-tweet" or share this article that many times too?).

So, with two weeks to go before the public comment window closes on August 12, 2012, please allow me to share my list of public comment "Dos" and "Don'ts" with you in the hopes that the effort you make to submit a comment will produce something actually worth reading by the evaluators or the Independent Objector.

First, please DO at least ONE of the following:

1) Post a comment that highlights, (with some specifics, please), either the merits or weaknesses of an application. For example, explain why an application doesn't adequately address how the applicant is technically, operationally, or financially capable to run a registry or point out that the applicant's answer to Question 18(b) is well reasoned, thoughtful, and indicative of success for the string.

2) Praise the specific experience or credentials of an applicant and also explain why that applicant should become the registry operator of that string.

3) If you know that you do NOT have standing or grounds to file a formal objection under ICANN criteria, go ahead make your criticism or objection known (but otherwise see the corresponding "DON'T" below).

4) If you are a supporter of a community-based application, explain why that community is valuable to you and why the applicant will promote your interests. Additionally, if that community application is in contention, explain why it should receive a score of 14 points in the evaluation process to qualify as a community-based application.

Second, please DON'T do ANY of the following:

1) Write a comment that supports your own application. Of course you support it, otherwise you would not have applied. It's self-serving and will not be given any weight.

2) Make an objection if you know that you have standing or legal grounds to formally object. You have plenty of time to do that later. Conserve your ammunition for the objection. A "public comment objection" will not likely scare off the applicant.

3) Say you are an "impassioned" supporter of an applicant or "disapprove" of another applicant. Instead, please offer something concrete.

4) Be overly or vehemently critical of another competing applicant for your string. The comment will be seen as desperate and undermines your credibility. Better to encourage third parties to be the critical voice against your competition, although your orchestration of such criticism will probably also be obvious.

5) Criticize the new gTLD program, generally. Bashing ICANN is already soon to be another insane real Olympic sport but don't do it here. You can, however, post general comments on the Feedback Forum and, of course, you are most welcome to offer a brilliant idea for managing the application evaluation process like how to deal with batching.

If you are able to follow these "Dos and Don'ts," many will thank you.

I look forward to reading your public comments in the coming days.

Statton Hammock is the former Sr. Director of Law & Policy at Network Solutions and currently provides legal and policy support and strategic business advice to new gTLD applicants and others in the domain name industry. His personal favorite new gTLD application is for the extension ".ninja.

By Statton Hammock, Vice-President, Business & Legal Affairs, Rightside

Related topics: Domain Names, Registry Services, ICANN, Top-Level Domains

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Ms.Holme We Salute You Robert Rozicki  –  Aug 01, 2012 7:27 PM PDT

Very cool post Statton, I will retweet it but just once :) Ms Holme tactics should have been in the things not to do list. I'm not sure of her process of choosing applications to post her suggestions on but it looked a little scatter gun. I also think the "this was used by .xxx so it should work for everyone" approach is a little narrow sighted. Blocking is something that creates a terrible internet user experience which is probably doing more damage to the brand that by just protecting the name and point it somewhere safe.

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