ISP & Connectivity Providers Constituency
Constituency Comments on New gTLD Program – Draft expression of Interest/Pre-Registrations Model

The ISPCP welcomes the opportunity to comment on the Draft expression of Interest/Pre registration model.
The new gTLD program will have a strong impact on both ISPs and Network Operators, and the ISPCP considers the stability and security of the DNS is of prime importance to ISPs and the community that it serves.
The ISPCP welcomes the Expression of Interest concept as it is a factual and may be only way to measure and provide the necessary information on the level of demand for new gTLDS of different categories.
The data collected should help clarify and solve in an easier way two of the overarching issues: 
-	Economic demand and impacts
-	Root scaling issue.
It will also provide to ISPs and Network operators useful information that will  assist in preparing  for this fundamental change.
In order to obtain data that will be fully representative, and to avoid gaming, the EoI should be mandatory for the first round of applications, and for the same reason, a deposit should be required.
The ISPCP supports the principle that the deposit should be refundable if the new gTLD program does not launch within a specific period of time.
We understand that there may be amendments to the Applicant Guidebook and major changes to the RFP following the analysis of the results of the EoI. In cases where the required amendments are significant according to the nature of an application, (string or category of application/applicant), the deposit should be refunded  to the applicant. The EoI objectives are to clarify and have a better view on the impacts of the RFP related to the overarching issues. As a consequence we do not see the value of making public the participant and string information without the explicit consent of the requestor.
Such disclosure without any mechanism in place like appeals, contention resolution, etc, will result in confusion orlegal actions without any mechanism in place to address them, and create a lot of confusion and uncertainty. 
A potential applicant should be authorized to request confidentiality on the string requested and on its identity, and public information should be restricted to what is necessary for the community to address in an efficient way the overarching issues.
The Expression of Interest should aim to help to solve or to have a better view on overarching issues, not to create more confusion in the process, nor to further delay the process for gTLDs expansion.
The Expression of Interest should be launched as soon as possible and no later than 2010.