Application Comment Details

PUBLIC COMMENTS FOR THE ICANN FINANCIAL EVALUATION PANEL ON THE APPLICATION SUBMITTED BY UNIFORUM ZA CENTRAL REGISTRY FOR THE

.AFRICA GENERIC TOP-LEVEL DOMAIN NAME

COMMENTS SUBMITTED BY DOTCONNECTAFRICA TRUST

On the Possible Conflict in the Business Model of a ccTLD Registry Operating a Continental-level gTLD

DCA Trust believes that the .Africa new gTLD application submitted by UniForum ZA Central Registry raises grave concerns regarding the possible conflicts in the business model of a ccTLD Registry Operator also applying to operate a Continental-level generic Top-Level Domain. UniForum ZA Central Registry has been undertaking the domain administration of the .co.za second-level domain under the South Africa (.za) country-code Top-Level Domain (ccTLD).

DCA Trust believes that the role of the ccTLDs should be strictly limited to managing and administering the country code TLD, and should have no involvement whatsoever in the management and administration of a continental Top-Level Domain such as .Africa. If the Internet Governance Model does not allow the ccTLDs to own a Continental gTLD, we do not believe that an organization such as UniForum ZA Central Registry that is operating as a ccTLD registry (.co.za Domain Administration – Please see http://www.registry.net.za) should also be involved in applying for the administration and management of the new .Africa gTLD. We think that an African country ccTLD registry service should not participate as a registry operator at the country-code level and also at the continental level. In other words, operating as a ccTLD registry operator should immediately disqualify it from undertaking the registry operation of a continental gTLD.

We therefore urge the ICANN Evaluation to look into the possible conflict in a second-level ccTLD domain name registry operator also wishing to engage in operating the registry of a Continental Top-Level Domain.

DCA Trust believes that such a serious conflict provides sufficient grounds for the outright rejection of UniForum ZA Central Registry’s application for the .Africa new gTLD.