NCSG response on RA comments

[Avri Doria <avri@xxxxxxxx>]

To the ICANN Board and Staff.

Without agreeing with every argument presented, NCSG strongly supports the 
argument contained in the Versign comment that the new powers ICANN is granting 
itself without a legitimizing Policy Development Process, are the antithesis of 
the multi-stakeholder bottom-up organization ICANN tries to sell itself as.  
NCSG agrees with Chuck Gomes in that we are also “fundamentally opposed to any 
extraordinary amendment process.”  NCSG is fundamentally against any 
contravention to GNSO Policy Development Process.  We further express our 
agreement with the statement:
                                                
The proposed 7.6 language introduced on February 5, 2013, the proposed "Public 
Interest Amendment," the proposed "Extraordinary Amendment Process" introduced 
on April 1, 2013, and the newly introduced 7.7 language all amount to the same 
thing: A unilateral right permitting ICANN to amend provisions in the new gTLD 
Registry Agreement. 

As a Multistakeholder organization, ICANN Board and Staff should never be able 
to make unilateral changes to binding documents, especially when those changes 
will give it unilateral powers in perpetuity.



Avri Doria
Alternate Chair NCSG Policy Committee
Submitted on behalf of NCSG