Comments on IRP suplementary procedures

["Perez Galindo, Rafael" <RPEREZGA@xxxxxxxxxx>]

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.