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DotGreen's Comments on new gTLD GAC Advice for Safeguards

  • To: comments-gac-safeguard-advice-23apr13@xxxxxxxxx
  • Subject: DotGreen's Comments on new gTLD GAC Advice for Safeguards
  • From: Annalisa Roger <annalisaroger@xxxxxxxxxxxx>
  • Date: Tue, 14 May 2013 13:49:55 -0700

RE: DotGreen's Comment on new gTLD GAC Advice for Safeguards

DotGreen fully supports the ICANN multi-stakeholder model, strongly
believing that all active members of the ICANN community have a voice in
ensuring benefit for the public interest and Internet user.  The GAC plays
an important role as they represent the governments all over the world.

In its Beijing Communiqué, specifically as it relates to Safeguards on New
gTLDs, the document states “The GAC advises the Board that all safeguards
highlighted in this document as well as any other safeguard requested by
the ICANN Board and/or implemented by the new gTLD registry and registrars

-         Be implemented in a manner that is fully respectful of human
rights and fundamental freedoms as enshrined in international and, as
appropriate, regional declarations, conventions, treaties and other legal
instruments – including, but not limited to, the UN Universal Declaration
of Human Rights.

-         Respect all substantive and procedural laws under the applicable

-         Be operated in an open manner consistent with general principles
of openness and non-discrimination.”

DotGreen understands the position that the GAC is taking relating to human
rights and freedoms, international laws and operating in an open and
non-discriminatory fashion.  DotGreen supports this concept in general that
all Internet users should expect this in the implementation of top-level

DotGreen feels like these general guidelines can be accomplished within the
framework of the existing Applicant Guidebook (AG), the current Registrar
Accreditation Agreement (RAA) out for public comment and the Registry
Agreement (RA) out for public comment.  It does not appear any changes to
the New gTLD Program would need to be implemented.   If ICANN proceeds with
the AG, RAA and RA as they exist today, then this should ensure the above
general GAC principles overarching the Safeguards would be included, their
Advice taken and ensure that the Internet user is being served in a
positive way benefiting the public at large.

It is DotGreen’s comment and suggestion that ICANN take GAC Advice where
immediately possible and not let the details of the Safeguards and Annex I
delay the New gTLD program.  Further study and consultation should happen
only as necessary and as suggested by the GAC in some areas of their
Advice.  However, this should not slow down or delay the acceptance of
other GAC Advice and implementation of the New gTLD program nor the
progress of launching some New gTLDs free from further discussions.
Thank you for this opportunity to submit comments.

Annalisa Roger, Founder/CEO
Cell: 415.730.5736

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