Application Comment Details

Don Moody
New gTLD Disputes
HOTEL Top-Level-Domain S.a.r.l
Community Evaluation Panel
Community Priority Evaluation for .HOTEL
5 March 2014 at 17:08:28 UTC

To Whom It May Concern:

Subject: Community Priority Evaluation for .HOTEL

This comment is being submitted on behalf of Donuts Inc. ("Donuts"). Donuts supports the analysis and conclusion of Minds + Machines submitted to ICANN regarding the Community application of HOTEL Top-Level-Domain S.a.r.l’s Application for .HOTEL.

In this case the applicant has contrived to create a “hotel community” in order to take advantage of the new gTLD program policy to protect genuine community interests. We agree with Minds + Machines that the proposed community is ill-defined, allowing in marketing organizations that are not “hotels” and excluding bed and breakfasts that are “hotels.” Even if that contrivance were not cured, the policy is meant to protect bona fide communities such as native aboriginal and cultural groups and not this particular group of hoteliers and their support groups that have a commonality of interest but not the “cohesion” described in the Guidebook.

If anything, we believe that Minds + Machines was generous in their scoring.

• This .HOTEL application should not receive a point for “Extension” as the community as they have defined it does not have the specific and clear age and size boundaries that are required.

• This .HOTEL application should score zero points for "Nexus" (not two). Because the application only reaches a portion of hoteliers (excluding, among others, bed and breakfast operators) it is overreaching. The Guidebook indicates such over-reaching merits zero points.

Donuts does not dispute that the HOTEL Top-Level-Domain S.a.r.l’s application in general is competently executed or that several organizations have supported this application. However, more than this level of support is required to meet the specific Applicant Guidebook community criteria. The bar has been set deliberately high to avoid the use of the community label by those seeking to use it to exclude other bona fide applications. The generic word “hotel” cannot describe a community as defined by the new gTLD program. The CPE analysis by an independent panel should easily demonstrate that.


Don C. Moody, J.D., M.S.

New gTLD Disputes

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