Comments on IRP suplementary procedures
Thanks for the opportunity to comment on the draft IRP supplementary procedures as foreseen in https://www.icann.org/public-comments/irp-supp-procedures-2016-11-28-en. The selection of English as primary working language may hamper the implementation of the diversity principle that drives the IRP (Bylaws Section 4.3(j)(iv): Reasonable efforts shall be taken to achieve cultural, linguistic, gender, and legal tradition diversity, and diversity by Geographic Region of the standing panel). Hence, appropriate measures should be put in place with regards to provision of translation services for Claimants, in order to warrant a level playing field in the process. The following aspects could be added to the supplementary procedures: a) Interpretation services should be granted and provided at no charge if requested by the Claimant. b) Any documents submitted in English should be accompanied by a translation in whole or in part into the language requested by the Claimant. c) For the purpose of calculating a period of time under these Rules, such period shall begin to run on the day following the day when a notice or other communication is received, only if the translated documents referred to in the above letter have been sent to the Claimant. Otherwise, the period shall only begin to run when the aforementioned documents have been received. I kindly ask that these comments be taken into account by the drafting team. Best regards Rafael Pérez Galindo Spanish GAC Rep.