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 a pragmatic approach and, going forward, possibly the only reliable way to measure the level of demand for new gTLDS of different categories.
The data collected will help clarify and address two of the overarching issues: 
-	Economic demand and impacts
-	Root scaling issues.
It will also provide to ISPs and Network operators useful information that will  assist in preparing  for this fundamental change.
For the EoI data to 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 is not launched within a specific period of time that would be known to all EoI candidates.
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. It is indeed important to assess the interest of the community for this process and amend the process accordingly to better serve it. However, if such amendments are required and have a significant impact on a particular application because of its nature or characteristics (eg string or category of application/applicant), the deposit should be refunded  to the applicant. 
The EoI objectives are to clarify the impacts of the RFP related to the overarching issues. In this respect, we do not see the value of making public the participant and string information without the explicit consent of the requestor. Knowing the character string and the requestor's identity will not help evaluating the impacts for the above issues.
Worse, in the absence of mechanisms in place like appeals, contention/dispute resolution, etc, such disclosure will result in confusion or legal actions without any mechanism in place for the potential application and/or its contender(s) to address them. This can only create confusion and uncertainty. 
A potential applicant should therefore be granted confidentiality for the string requested and/or on its identity if it so requests 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.