The 45 day/12 months time limits seem unreasonably short
The proposed limits on filing - 45 days after becoming aware (and within a 12 month limitation window) are significantly too short.
Given the significant and evolving complexity of ICANN's structure and its layers of organic documents and procedures, only the most affluent of people or organizations could comprehend, research, and write a proper submission in a mere 45 days. As a consequence these time periods effectively shut out most members of the internet community - and, correspondingly, will increase the relative authority of those interests that have enough money to hire services - usually in the form of a large and expensive law firm - to react within the small time window.
By-the-way, are those 45 days calendar days or business days?The twelve month limit will act as a kind of concrete that locks-in decisions in which the ill aspects take a long time to emerge and be understood. Moreover, many aspects may not emerge until put into actual practice; and we know from experience that in ICANN, it often takes years to transform a decision into practice so that its effects may be perceived. In addition, if an action of ICANN violates its principles then the door to correction ought to never be closed.
The 45 day period ought to be changed to be least six months (180 days) after awareness; and the 12 month limit ought to be at least doubled, or better, removed entirely.
--karl-- Karl Auerbach(Former publicly elected member of the ICANN Board of Directors for North America)