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Lack of Transparency in RAA Change to 3.3.6

  • To: <comments-proposed-raa-22apr13@xxxxxxxxx>
  • Subject: Lack of Transparency in RAA Change to 3.3.6
  • From: "Garth Bruen" <gbruen@xxxxxxxxxx>
  • Date: Mon, 27 May 2013 00:30:31 -0400

This comment is submitted on behalf of our membership and community

The proposed changes to RAA 3.3.6 arrived from an unknown origin and without
prior disclosure. The September 2012 Summary Chart of RAA changes makes no
reference to changes to 3.3.6 (see:
6200000).  There is no discussion of the proposed change in the join
GNSO-ALAC Final Report (see:

Various requests of  staff to provide more details on the "additional
proposed changes which have not yet been negotiated" mentioned in a December
2012 announcement (see:
were met with delay until March 2013 when the full list of changes was
posted. The source of the change to 3.3.6 is cited as "ICANN economic
advisors", an unknown party to the negotiations. They apparently based their
decision on an "economic study." The advisors are not named and the study is
not posted. 

On a March 18 2013 ALAC briefing call on RAA changes staff was asked to
identify the economic advisors and cite the study document but were unable
to do either. A request was made on this call to produce the document and
more details about the economic advisors but there has been no follow up
from staff (see:

The conditions of this contract change are completely non-transparent and
should be dropped from the new version of the RAA. This is something
obviously not driven by any consensus policy and was not discussed publicly.

Thank you. 


Garth Bruen

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