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[wg-c] Introduction and unofficial proposal




 I've been a silent reader of the wg-c list so far (though only actually
joined the list a few weeks ago.)  I am a Harvard Law Student and I am
organizing a panel for the Berkman Center for Internet and Society
pre-ICANN meeting conference taking place on Oct. 31st in LA.  This
proposal (hopefully revised in light of your comments) is going to be
the starting point for a moderated panel discussion. (moderator =
jonathan zittrain.)  It is not meant as a compromise, but rather the
solution that makes the most sense to me after listening to the
arguments you have made.  

    Looking for feedback, Rebecca Nesson

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Proposal for Competition in the Top Level Domain: Analysis of Public
Comment 

Rebecca Nesson
Harvard Law School


This proposal is intended to provide a focal point for the panel
discussion of the addition of new gTLDs at the Berkman Center for
Internet and Society conference on the
issues facing ICANN.  Substantively it is based on the discussions that
took place in DNSO Working Group C and the position papers that
represent the views of the participants.  While Working Group C did not
reach consensus, there was much constructive discussion and the papers
present a diversity of views and some possibilities for constructive,
concrete solutions.


1.  ICANN has the authority and the mandate to address the addition of
new gTLDs.

This is a necessary premise for ICANN's constructive consideration of
the issue.  It was also widely accepted within Working Group C.  As
Mueller argues in his proposal, this authority is also clearly
contemplated by the United States Government. 

"Adding new gTLDs to the root is an important part of ICANN's mandate. 
The Department of Commerce White Paper included 'oversee policy for
determining the circumstances under which new TLDs are added to the root
system' as one of the 4 key purposes of the new corporation.  Thus,
ICANN's handling of new TLDs is an important test of its DNS
stewardship." (Mueller Proposal) 

"The assignment and delegation of a gTLD registry is subject to the
ultimate authority of ICANN." (Simon Proposal)

2.  New gTLDs should be added to the root.

There is broad consensus that new gTLDs should be added to the DNS root
in order to increase availability, choice and competition.  Trademark
interests prefer not to add more gTLDs, but if there are sufficient
safeguards for trademarks in the new spaces, the substance of their
concern will have been addressed.  

"Expanding the number of TLDs will increase consumer choice, and create
opportunities for entities that have been shut out under the current
name structure.  If the name space is expanded, companies will be able
to get easy-to-remember domain names more easily, and the entry barriers
to successful participation in electronic commerce will be lowered.
Similarly, addition of new gTLDs could enlarge noncommercial name
space." (Weinberg Proposal)  

"[U]nder the current applications of Internet technology, mnemonically
and semantically useful domain names have become an important and
convenient tool of human communication… [E]xpansion of the gTLD space is
necessary to ensure there will continue to be an abundant choice of
names available for people who wish to acquire useful Internet
identifiers…[E]xpansion of the gTLD space is also necessary to ensure
that current Internet users and newcomers alike will be afforded the
continuing opportunity to communicate by way of domain names which have
mnemonic and semantic utility…[and] that domain names themselves are
often used as mechanisms for conveying normative expressions and
opinions." (Simon Proposal)
  
"Once these safeguards have been adopted and are shown to be effective,
we believe new gTLDs may be introduced, in necessary, provided they are
introduced in a slow and controlled manner followed by an evaluation
period before any further new gTLDs are added." (Chicoine Proposal)

"There is abundant evidence of significant end user demand for expanding
the name space.  Second-level domain names under the dot com TLD
routinely change hands for enormously inflated prices.  High prices
reflect the artificial scarcity of common names in existing gTLDs, and
the premium on .com names in particular.  There are widespread
complaints among users that it is becoming increasingly difficult to
find simple domain names in the NSI gTLDs.  Currently, the weekly growth
rate of domain name registrations is over 270,500.   Current gTLDs
simply will not be able to contain such growth."  (Mueller Proposal)

"[T]here is a need for multiple new gTLDs, not for competitive reasons
per se, but instead to support the multiple registries needed for
stability."  (Crispin Proposal)

 3.  ICANN should authorize the addition of as many new gTLDs as are
technically feasible and operationally stable. 

"In the long term, a domain name system with a large number of gTLDs
seems highly desirable.  Each additional TLD provides new options for
domain-name registrants.  Further, a name space in which there are many
TLDs and TLD registries is one in which the registries themselves are
(or can be) subject to useful market competition.  The existence of many
competing TLD registries will diminish the market power that any
particular TLD will exercise.  Users who are unimpressed with the
performance of one registry can instead acquire a new domain name in a
different top-level domain, run by a different registry.  Members of the
Internet community will be able to decide themselves, through their
name-registration decisions, which of the many possible TLDs will play
an important role in the name space. It would be undesirable to
artificially limit the number of gTLDs short of the bounds of the
technically feasible and operationally stable."  (Weinberg Proposal)

The Mueller Proposal embodies many of the same ideas, but instead
proposes the up front announcement of an intention to add 500 new gTLDs.
If the Weinberg Proposal is read to presume that many more gTLDs will be
added after the initial rollout, it achieves this goal. 

"The WG-C's report to the DNSO proposes to add only 6 - 10 new gTLDs to
the root as a 'testbed.'  It would then engage in an evaluation period
before adding any more.  There is no commitment or presumption that more
would be added. We believe that the proposal is far too limited and
imposes undue restriction on competition, innovation, and cultural
diversity. The most important reason to specify at the outset a specific
and large number of gTLDs is to ensure a competitive market and a level
playing field in the provision of domain name registration services
under new gTLDs.  A pre-announcement of a large number makes it clear
that the initial winners of new gTLD awards can anticipate plenty of
additional competition.  Investment and entry decisions of new
competitors will be far more rational.  Consumption decisions will be
based on the need for an value of the domain names themselves, not on
attempts to exploit artificial scarcity."  (Mueller Proposal)

Trademark interests would prefer not to add an unlimited number of new
gTLDs.  However, their concerns lie in the ability to protect their
trademark interests, and if sufficient dispute resolution processes are
in place, the number of new gTLDs should be immaterial.    

Although the Crispin Proposal does not share the goal of market-type
competition between TLDs, it is not at odds with adding a large number
of new gTLDs.

"This model ["Internet Stability model"] makes no presumption about the
ultimate desirable number of TLDs, except in that it seems necessary to
add more TLDs in the near (1 to 3 year) time frame to develop the
infrastructure needed for stability."  (Crispin Proposal)

4.  These new gTLDs should include both general-purpose TLDs and
limited-purpose TLDs.

By way of definition "general-purpose TLD" refers to a TLD in which
anyone may register, while a "limited-purpose TLD" is one in which the
registrants must meet a set of criteria specific to TLD.  Registrants
who fit limited-purpose TLD criteria will not be restricted to that TLD
or precluded from registering in open gTLDs.  (For example, airlines
could register SLDs in ".airline" and/or in ".com")

"Fundamentally the nature of the new gTLDs would not preclude solutions
to the problems introduced by the introduction of political geography as
the one of two prevailing mechanisms for the organization of the DNS
name space.  Neither should the nature or the new gTLDs preclude
solutions to the problems induced by reliance upon monopoly control over
some portions of the thematic DNS name space.  To this end the new gTLDs
should include both commonly understood forms of TLDs.  There should be
both "open" gTLDs, and "chartered" gTLDs (aka "restricted" or
"sponsored").  (Brunner Proposal)

"[L]imited-purpose TLDs give more information to the consumer and will
be less threatening to trademark interests opposed to the expansion of
the name space. [L]imited-purpose gTLDs can be useful. [These should not
be the only new gTLDs.  Alternative general purpose top-level domains
could provide effective competition to .com.  This would more nearly
level the playing field for individuals and businesses seeking
attractive domain names. [T]he ideal system would be one that mixes new
limited-purpose gTLDs with new general-purpose ones."  (Weinberg
Proposal)

5.  Before or coincident with the authorization of new gTLDs, ICANN
should ensure that there will adequate protections for trademark
interests in the new TLDs.  

The appropriate substance of adequate trademark protections is
complicated, contentious, and beyond the scope of this proposal.  It
involves difficult questions of the applicability of trademark law to
non-commercial uses, privacy concerns of domain name registrants, and
jurisdictional issues of which law should apply.  While it cannot be
decided here, it also cannot be ignored because a satisfactory
resolution of that issue is a necessary condition for making this
proposal acceptable to trademark interests.  

The Chicoine Proposal recommends:

Adequate protection for trademarks should include:
a.	Reform of registration protocols that create a centralized whois-type
service;
b.	A speedy and effective Uniform Dispute Resolution Policy; 
c.	Additional resolutions regarding the protection of famous marks in
the name space. 

If this or another more widely acceptable policy is followed it should
address the concerns of trademark interests adequately, thus making
their concern about increasing the name space irrelevant.  

"It is legitimate for the trademark and intellectual property interests
to advocate case-specific dispute resolution procedures to protect
themselves from abusive domain name registrations.  It is not
legitimate, however, for trademark holders to demand what amounts to a
blanket prohibition on entry into a market for a legal service (domain
name registration) solely to make their policing and enforcement task
cheaper and easier.  Such a policy unfairly imposes costs and
restrictions on millions of innocent consumers and suppliers.  Operating
a TLD is not, per se, abusive or infringing; infringing and speculative
name registrations constitute a tiny fraction of the total number of
registrations in any TLD."  (Mueller Proposal)  

"We strongly believe that the question of how many gTLDs should be added
and how fast, should not be addressed until appropriate safeguards are
in place in the form of i) improved domain name registration procedures;
ii) implementation of speedy and effective uniform dispute resolution
procedures for abusive registrations; and iii) adoption of a system for
protecting famous and well-known trademark across all gTLDs.  We
strongly support WIPO's conclusion that there is a need for improvement
of the registration practices in the Domain Name System (DNS), and in
particular, centralized access to the "WHOIS"-type data.  The lack of
reliable information about domain name registrants dramatically
increases the amount of time and money expended by intellectual property
owners in defending their intellectual property against abusive domain
name registration.  Such limitation only serve to encourage abuse of
intellectual property rights, frustrate the effective enforcement of
legitimate intellectual property rights, and inevitable, increase the
cost of doing business on the Internet for the end user, as well as
reducing their confidence in the same. We believe access to the data
must be centralized in light of the number of registries being
accredited by ICANN.  While we agree that ICANN must quickly move to
implement systems that will thwart, if not eliminate, the cases of clear
abuse, we also believe the ICANN must develop procedures that will
adequately address situation where owner of legitimate trademark rights
in the real world marketplace come into conflict within the DNS of the
virtual world marketplace.  [W]e strongly support WIPO's recommendation
that development and implementation of an administrative dispute
resolution procedure will assist in alleviating the problems currently
faces by all intellectual property owners under the current DNS.   By
instituting a dispute resolution procedure, ICANN will provide
intellectual property owners with a cost effective and speedy option for
resolving domain name disputes without the onerous task of resorting to
litigation.  [W]e agree with the WIPO recommendation that ICANN
implement a procedure designed to protect famous and well-known
trademarks."  (Chicoine Proposal)

"With the present churn regarding trademark rulings and issues, it is
becoming ever more vital that the registry remove its business operation
as far as possible from these contentious issues. The registry should
not support any form of arbitration directly or otherwise embroil itself
in that political debate. It should require the presentation of a court
order, from a court of competent jurisdiction, prior to acting on any of
these issues, and otherwise remain strictly neutral."  (Meyer Proposal)


6.  The new TLDs should be added in a gradual introduction phase that
incorporates evaluation and opportunities for change within the
procedure.  

Initially ICANN should authorize the introduction of 6 - 10 new TLDs,
and then after a test period, accept applications from prospective
registries.  It should be clear from the outset that the presumption is
that ICANN will continue to add more registries after the initial test
period.

"It would not be sensible to dump a huge number of new TLDs into the
namespace on Day One.  Rather, ICANN should supervise a smooth
transition to an expanded namespace.  [ICANN should] announce a test bed
in which a fixed number of new registries would be added to the root,
followed by an evaluation period.  Assuming the testbed revealed no
major problems, it would them move to a phased rollout in which new TLDs
would be added to the root as qualified registries applied to run them,
but no mare than a fixed number would be added per month.  The per-month
"cap" would ensure that new TLDs would not be added so quickly as to
overwhelm ICANN's processes or the new dispute-resolution system." 
(Weinberg Proposal)

"[W]e believe new gTLDs may be introduced, if necessary, provided they
are introduced in a slow and controlled manner followed by an evaluation
period before any further new gTLDs are added.  The evaluation must
include all technical and legal aspects of the new gTLDs and registries,
in order to make any necessary amendments of rules and conditions.  Only
after assessing the results of the evaluation should it be possible to
add more, if needed."  (Chicoine Proposal)


7.  Initially each registry should be allowed to operate only a single
TLD.  

In the future registries may apply for additional TLDs or groups of
registries may apply for groups of TLDs if they believe a shared TLD
model is best.

This is another fundamental point of contention between the Weinberg
Proposal supporters and the Crispin Proposal supporters.  The Weinberg
Proposal allows for the co-existence of both models while the Crispin
Proposal allows only for its own registry structure.  Fortunately, the
Crispin Proposal makes both its ultimate goal and its means for reaching
that end clear.  While the Weinberg Proposal does not use the same
means, with some modification it can reach the goal.  

"[T]his proposal concentrates on the area of Internet stability." 
(Crispin Proposal)

"[ICANN] should limit each qualified new registry, at the outset, to a
single gTLD.  This will allow the greatest number of entities to
participate in the transition, and generate the most 'bang for the buck'
in new registry competition." (Weinberg Proposal)

Under the Weinberg Proposal, a group of registries operating in the
public interest may operate a group of gTLDs in exactly the manner
described by the Crispin Proposal.  If this system should turn out to be
the more stable, and thus the superior, end user choice will indicate
that through registration decisions.  Any registrant within those gTLDs
will be ensured the Internet stability envisioned by the Crispin
Proposal.  

8.   Registries should apply for the gTLD they would like to operate.  

"ICANN should not impose any specific model upon registries, nor should
it centrally impose any specific pattern of names.  It should allow the
choices of end users in the marketplace to decide which models and names
succeed and which fail.  The content of the top-level name space should
be driven by applications submitted by prospective registries." (Mueller
Proposal)

"The proposal will state the TLD strings that the registry wishes."
(Stahura Proposal)

Other proposals indicate a preference for ICANN choosing the names of
the new gTLDs.  

"Allocation of TLD names to registries should not happen until after the
registry operators are selected, and should be done through a completely
independent process - perhaps random selection."  (Crispin Proposal)

"We believe that ICANN should decide on a set of new gTLD strings, and
then solicit applications from would-be registries (or existing
registries) to run those TLDs."  (Chicoine Proposal)

The Mueller Proposal is advantageous because it prevents ICANN from
making substantive decisions about the content of the name space while
allowing a diverse group of names to enter the space.  ICANN's task in
this area would be limited to mediating disputes between applicants
seeking the same TLD.  This mediation could best be performed by setting
up mediation or dispute resolution guidelines and applying them on a
case-by-case basis. 

9.  While gTLDs will receive the exclusive right to operate the gTLD,
they will not receive (nor will ICANN recognize) any trademark interest
in the gTLD itself.  

As part of ICANN's need to maintain Internet stability and
interoperability it must be able to negotiate with registries when
problems arise free of the constraints of intellectual property
interests in the gTLD itself.  

"The Internet naming system is a public resource and the TLD space is an
essential facility of the public Internet.  Correspondingly, the
management of the root zone and of gTLD registries must be performed on
behalf of the public interest in a manner that ensures the world-wide
interoperability of unique Internet identifiers and their traceabilty
back to the Internet's publicly coordinated root.  Accordingly, no
private intellectual or other property rights inhere to an assigned gTLD
itself, not accrue to the delegated managers of the gTLD as the result
of such delegation."  (Simon Proposal)

"The model argues against "proprietary" TLDs, because of the potential
legal difficulties in moving the registry data from one registry to
another." (Crispin Proposal)

10.  Criteria for registries should be restricted to technical ability
and financial stability. Beyond its duty to ensure Internet stability
and interoperability and to administer dispute resolution procedures,
ICANN should refrain from making substantive judgments about registries.


"Competition in the marketplace and user preferences will determine
which approaches succeed.  Regulatory and legal remedies to consumer
protection problems that develop should be left to professional
regulators in national governments.  ICANN should concentrate
exclusively on technical and administrative interoperability, and
accountability.  It should establish basic qualifications for top-level
domain name registries, and these should be confined exclusively to
technical stability and financial responsibility." (Mueller Proposal)

"What is most important is that ICANN adopt a policy under which it is
relatively easy to get new gTLDs into the root (whether operated by a
newly created registry or an already-existing one).  Thus, ICANN's
criteria for the qualification of new registries should not be
unreasonably burdensome." (Weinberg Proposal)

11.   ICANN should mandate that each registry maintain and update copies
of their root zone files and additionally maintain a mirror of the
registry in at least two secure and geographically spread locations. 
Upon failure to provide an adequate percentage of "up time" the registry
must submit to pre-designed remedial procedures.  

Many of the proposals indicate the need for Internet stability and
interoperability.  These goals can be achieved through ICANN's
requirements for registries. 

"The basic question of stability is 'what happens if the registry
becomes unavailable'?  [A] long term breakdown in the registration
process would have serious impact, and loss of the registration data
could lead to chaos. [This proposal] concentrates on the fact that there
is a single point of failure for a critical service. The basic model is
of multiple registries, each capable of managing registrations for
multiple TLDs.  The registry data for each TLD is transportable, and
replicated or escrowed.  The destruction or unavailability of any
particular registry can be remedied by another registry taking over its
functions, within a time frame consistent with stability."  (Crispin
Proposal)

"[T]he management of the root zone and of gTLD registries must be
performed on behalf of the public interest in a manner that ensures the
world-wide interoperability of unique Internet identifiers and their
traceability back to the Internet's publicly coordinated root." (Simon
Proposal)

"ICANN should concentrate exclusively on technical and administrative
coordination of registry operators to ensure stability,
interoperability, and accountability."  (Mueller Proposal)

The Meyer Proposal recognizes that these goals may be achieved through
ICANN imposed standards:

"It is the root registry's prime directive to maintain the stability of
its operation, above all else.  In keeping with that primary directive,
the root registry needs to define process and structure by
which…registries may be added and under what conditions. [They must:]
1.	Develop requirements that a TLD registry MUST meet, a minimum TLD
SLA.  This SLA must be met on day one of operational birth, on a
zero-defect basis. 
2.	Restrict the TLD registry to one TLD until it meets solvency
requirements.
3.	Allow no more than 10 TLD registries, or 20%, whichever is greater,
to be on such "probation" at any single point in time.
4.	After a fixed period, if the registry cannot pass the solvency test,
its license gets retracted and becomes available to someone else."
(Meyer Proposal)

"The primary implementation mechanism of the root registry is the root
servers. The root servers must be globally visible at all times, on a
24x7 basis. Minimum system-wide uptimes exceeding 99.99% are expected as
normal. In order to accomplish this throughout the world, it is
recommended that the registry operate at least two separate root-server
sites per continental landmass, physically located on each continental
landmass, with sufficient separation between them. In addition, each
root server site should be multi-homed, via two separate links, to the
Internet backbone." (Meyer Proposal) 

12.  Registries must have or require their registrars to have a
pre-approved procedure for registering SLDs that fairly arbitrates
between registrants who choose the same SLD and prevents wholesale
registration of large numbers of SLDs by single entities.

"The proposal will state its "opening day" policy.  A fair policy where
the accredited registrars have equal opportunity to register names on
opening day is encouraged." (Stahura Proposal)

13.  Registries may be shared or unshared, as chosen by the registry
applicant. 

The Weinberg Proposal and others favor a presumption of shared
registries. 

"Sharing ensures competition, on a level playing field, in the provision
of registrar services.  In particular, but ensuring that somebody who is
skillful at providing registrar services will be operating in each TLD,
it provides some protection against the situation in which the registry
controlling a desirable TLD is clueless at providing registrar services.
Oh the other hand, sharing is not a panacea;…[I]t is possible to imagine
situations in which a sharing requirement would actually interfere with
the provisions o innovative services….In light of these concerns, it
would be sensible for ICANN to enunciate a presumption that all TLDs
support competitive registrars, thus generation the benefits of
registrar competition, rebuttable to the extent that a particular
registry makes a showing to ICANN there would be significant advantages
to some other arrangement." (Weinberg Proposal)

The Meyer Proposal highlights the disadvantages of requiring sharing:

"Newcomers to the DNS scene are Registrars they are not a registry nor
are they domains. They have none of the responsibility of managing a
root server network, or maintaining the zone file, but they get to
collect more than half the money. In return, all they perform is some
customer-facing functions and advertising/marketing stuff. They also
provide yet another insulating buffer between the customer and the real
registry. In this author's opinion, this is not a good thing for either
registry or registrant. It is strictly at the option of the registry
whether or not they chose to support registrars." (Meyer Proposal)

The Mueller Proposal points out that the benefits of shared registries
may be realized without interference from ICANN and, if actually the
superior model, will be recognized as superior by end user choice.  
This solution additionally frees ICANN of the responsibility of judging
the applications of registries who purport to need to be an unshared
registry. 

"End users and suppliers, interacting in a marketplace, [should]
determine the market structure of registries, registrars, and names, and
ICANN in turn [should] coordinate their activities.[ICANN] should allow
the choices of end users in the marketplace to decide which models and
names succeed and which fail.  The content of the top-level name space
should be driven by applications submitted by prospective registries. 
Registries should contract with registrars on a free market basis, with
no pre-ordained pattern.  Competition in the marketplace and user
preferences will determine which approaches succeed. Product
differentiation and innovation may require integration of the
registrar-registry function. Shared-registry TLDs are one option in the
marketplace. If consumers express a clear preference for the price and
service delivered by this model, then it will be emulated."  (Mueller
Proposal)

14.  New TLDs may be operated on either a for-profit or non-profit, cost
recovery basis, as chosen by the registry applicant.

"Both non-profit and for-profit registries have advantages.  The
advantage of non-profit registries lies primarily in the expectation
that they will be less inclined to exploit their market power at the
expense of domain-name registrant.  The advantage of for-profit
registries lies primarily in their greater incentives to operate
efficiently and offer innovative services.[I]t would make sense to have
a mixed system of nonprofit and for-profit registries."  (Weinberg
Proposal)

"It is absolutely clear that no one knows which business model will
prevail for any given registry or any given TLD. It is therefore
considered that any and all business models are equally valid, whether
for-profit or non-profit. It is not the business of the root registry to
evaluate business models, or even review them." (Meyer Proposal)

"We believe some registries would be run on a not-for-profit,
cost-recovery basis, and could operate any number of gTLDs.  Other
registries, however, could be run on a for-profit basis, and would be
limited to a mall number of gTLDs.  Assuming the proper safeguards are
in place, we see no problem with having for-profit registries."
(Chicoine Proposal)

"The proposal will state the "business" model (non-profit, cost
recovery, for-profit, sponsored, chartered, etc.) of the proposed
registry." (Stahura Proposal)

The Crispin Proposal differs in this respect as well.  The goals and
concerns expressed with respect to proprietary gTLDs may be solved by
technical requirements of interoperability, competition between
registries for registrants, and ICANN's power to impose sanctions or
price controls on non-compliant registries.  Additionally, it is
unlikely that any new TLD will be able to gain the inherent value that
.com enjoys, thus competition in itself should be a sufficient regulator
of prices.  

"The model argues against "proprietary" TLDs, because of the potential
legal difficulties in moving the registry data from one registry to
another.  It also argues against any form of monopoly by a registry
operator --  this may be controlled by requiring not-profit status, but
other mechanisms may be used (NSI is under price controls)." (Crispin
Proposal)

15.  ICANN should select the first group of new gTLDs and registries
according to an objective set of criteria that ensure
geographic/cultural/linguistic and business model diversity.  
  
ICANN should make an effort to approve the most diverse set of new
registries possible in the initial rollout phase.  After that all
registries that meet the technical ability and financial stability
criteria should be approved.  

"How should ICANN proceed during the testbed and phased rollout, to the
extent that more registries seek immediate inclusion of their preferred
gTLDs than the schedule will accommodate?  There is no especially
satisfactory answer to this question; by hypothesis, some qualified
applications will have to be deferred.  None of the available paths to
decisions are ideal.  The process that would likely make ICANN itself
most comfortable would be an ad hoc selection process under which ICANN
was free to look to a variety of factors, including both the
qualifications of the registry and the nature of the TLD.  In the long
term, such an approach would not be desirable; it presents the risk of
subjective and unaccountable decision-making.  In the short term,
however, as a matter of supervising the initial rollout, it would be
responsive to oft-expressed concerns about Internet stability and
reliability." (Weinberg Proposal)

"The proposal will state the "business" model (non-profit, cost
recovery, for-profit, sponsored, chartered, etc.) of the proposed
registry.  A diverse set of models/concepts is sought… The proposal will
state the geographical area in which the registry operates. Again,
diversity is sought…ICANN will use the proposal information, weighing
all of the many inter-related issues to choose the initial set of
registries." (Stahura Proposal)