[ALAC] URGENT: Suggested ALAC statement related to my recent Public Comment

[Evan Leibovitch]

Hello all,

Following up to discussion this morning, I am presenting a proposal for a
second statement related to the Applicant Guidebook, for ALAC consideration.

If ALAC is to approve this it needs to be done before the deadline for
public comment tomorrow.

Here is the wiki link:

https://community.icann.org/display/atlarge/Additional+ALAC+Statement+on+Draft+Final+Applicant+Guidebook
>

As it its possible that there may be a problem with the wiki as it undergoes
maintenance later today, I am pasting the text below as well.

Please comment ASAP. We need direction from ALAC in order to potentially
approve this statement quickly (if that is indeed the wish of ALAC),

- Evan

-------------------------

The At-Large Advisory Committee ("ALAC") wishes to add an additional comment
on the Proposed Final Applicant Guidebook ("PAG"), to supplement comments
already endorsed and submitted as public comment.

Specifically, we wish to formally support both aspects of the comment made
by Alan Greenberg regarding the reduction of the URS response time noted in
the Universal Rapid Suspension ("URS") document, listed as an unnumbered
addendum to Module 5 (
http://www.icann.org/en/topics/new-gtlds/draft-urs-clean-12nov10-en.pdf).

Mr. Greenberg's comment exists in the public comment area for Module 5 and
may be viewed directly at
http://forum.icann.org/lists/5gtld-base/msg00005.html

As indicated in our previous statement, we have serious concerns regarding
what we consider to be backwards steps from areas of community consensus. As
one particularly serious example, we wish to draw attention to proposed URS
rules which appear to regress from the position taken by the cross-community
Special Trademark Issues ("STI") group and from the Draft Applicant
Guidebook version 4.

Although 14 days may be sufficient for large corporate entities, it is not
sufficient for registrants who are individuals, small businesses or
non-profit organizations -- particularly those located where mail delivery
is not as effective as in the US or western Europe. Given that the overall
URS process time had been reduced moving from the IRT and staff proposals to
that of the STI, there is no call for reverting to the 14 days. When public
comments to earlier rules were reviewed, the ICANN staff decision was to not
adjust the time period. This decision was presumably based on a few
complaints about it being to long, and a larger number about it being too
short.

As the STI process was one of ICANN's more successful efforts to bring
compromise to what were initially VERY opposing positions, it is disturbing
to have the Board micro-manage the issue at this level and late date.