Donuts sent ICANN a comment regarding the Community Priority Evaluation Application by GMO Registry, Inc. for .Shop New gTLD.
From what I have seen most community application have no merit, including the controversial .gay application. Companies get a few letters from a few organizations and apply for a community application just to avoid a bidding war with other applicants.
Here are a few highlights from the comment:
This comment is being submitted on behalf of Donuts Inc. (“Donuts”) concerning the above referenced New gTLD application (the “Application”).
Donuts supports and joins in the analysis of the Application recently submitted by Radix Registry (“Radix”).
To the extent it may further assist the Panel, Donuts highlights the deficiencies of the Application in the context of the community scoring criteria of the New gTLD Applicant Guidebook.
- The “Community” Is Not “Organized.”
- “[t]here is no worldwide coordinating body representing the entire community”
- The “Community” Is Neither “Clearly Delineated” Nor “Pre Existing.”
- The Application Cannot Ascribe a Size to the Alleged Community.
- The “Community” Has No “Longevity.”
The String .SHOP Does Not “Match” the “Name” of Any “Community.”
Donuts does not dispute that GMO’s application in general is competently executed.
However, more than this is required to meet the intentionally highly rigorous CPE criteria.
ICANN has deliberately set a “high bar” to avoid the use of the community label by those seeking to use it to exclude other bona fide applications (e.g. a “false positive”).
A generic word like “SHOP” cannot possibly describe a “community” as that concept is defined by the New gTLD program, and the CPE Panel should have little difficulty in finding that at least three out of the 16 possible points should be deducted to disqualify the Application from community priority.
Indeed, the analysis that Donuts has gone through herein shows GMO losing 13 of the 16 point otherwise available to it. Only five total points were awarded to the analogous strings. LLC, .INC, .GMBH and .LLP.
No more than three appear achievable here, but even if the number were four times as high, the Application would not and it cannot qualify for community priority.