Blacknight Comments on Proposed Bylaws Changes Regarding Consideration of GAC Advice

[Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>]

Dear Sir / Madam

I am submitting these comments in my capacity as founder and Managing Director 
of Blacknight, an ICANN accredited registrar based in Ireland.

The Internet Governance landscape is currently in a state of flux and ICANN is 
under considerable pressure from government, so it is understandable that the 
ICANN board may feel it necessary to consider this change to the bylaws.

However consideration of a change and enacting one are two very different 
things.

As can be seen from the bulk of the comments submitted on this topic to date, 
many members of the ICANN Community either have concerns or explicitly oppose 
this proposal.

We would be in a similar position at this time.

The Board's interactions with the GAC have evolved considerably over the last 
couple of years. The Board may reject GAC advice, but it has been doing a much 
better job of providing a clear rationale for doing so.

With respect to the GAC itself. As an organisation that interacts with ICANN it 
too is evolving, but at this juncture I would have serious concerns about 
giving GAC advice more weight than it already has. 
As things stand GAC advice is not taken lightly either by the Board or the rest 
of the ICANN Community. 

How would things pan out if GAC advice were to conflict with the outcome of a 
PDP? We've already seen how "well" that has played out on more than one 
occasion. This point has been highlighted by Mr Corwin's submission on behalf 
of the ICA:
http://forum.icann.org/lists/comments-bylaws-amend-gac-advice-15aug14/msg00012.html

We would also like to support the comments submitted by the Internet 
Infrastructure Coalition:
http://forum.icann.org/lists/comments-bylaws-amend-gac-advice-15aug14/msg00032.html

(Disclosure: I am on their board)

Regards

Michele
--
Mr Michele Neylon
Blacknight Solutions
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