Re: [gnso-igo-ingo] RE: Proposed Public Comment Period for Initial Report

[Thomas Rickert <rickert@xxxxxxxxxxx>]

All,
it is true that comment periods should not overlap with ICANN meetings. 
However, I guess that this is to make sure that ICANN meetings do not shorten a 
21 day comment period. 

In this case, we have proposed to have a longer comment period of 30 days 
because of the ICANN meeting. To be quit honest, I fail to see the benefit of 
having a shorter comment period only to have it ending before the meeting. 

In my discussions with Brian and Berry, we agreed it would be perceived a 
benefit to have the 30 days. Have we been so wrong?

Thomas 



Am 13.06.2013 um 18:02 schrieb <Mary.Wong@xxxxxxxxxxx>:

> I seem to recall some discussion within the GNSO community a while ago 
> relating to not having comment periods run during ICANN meetings. As such, 
> would it be possible to end the initial comment period just before the Durban 
> meeting, as Greg suggests, and start the reply period immediately after the 
> Durban meeting?
> 
> Thanks and cheers
> Mary
> 
> 
> Mary W S Wong 
> Professor of Law 
> Faculty Chair, Global IP Partnerships 
> Chair, Graduate IP Programs 
> UNIVERSITY OF NEW HAMPSHIRE SCHOOL OF LAW 
> Two White Street 
> Concord, NH 03301 
> USA 
> Email: mary.wong@xxxxxxxxxxx 
> Phone: 1-603-513-5143 
> Webpage: http://www.law.unh.edu/marywong/index.php 
> 
> 
> >>>
> From:
> "Shatan, Gregory S." <GShatan@xxxxxxxxxxxxx>
> To:
> "'Gomes, Chuck'" <cgomes@xxxxxxxxxxxx>, Brian Peck <brian.peck@xxxxxxxxx>, 
> GNSO IGO INGO <gnso-igo-ingo@xxxxxxxxx>
> Date:
> 6/13/2013 11:52 AM
> Subject:
> [gnso-igo-ingo] RE: Proposed Public Comment Period for Initial Report
> 
> Maybe it would make sense to end the initial comment period just a little 
> earlier (somewhere between July 10th and the 12th), so the period is clear of 
> Durban (+travel), commencing the reply period thereafter (and keeping the 
> reply period end date on August 4).  This would mitigate the tendency of 
> commenters to aim at the deadline,” and give a little more time to compile 
> and consider comments before the WG meets in Durban.  At the same time, it 
> accounts for the difficulty of dealing with drafting and Durban 
> simultaneously.
>  
> Greg
>  
> From: owner-gnso-igo-ingo@xxxxxxxxx [mailto:owner-gnso-igo-ingo@xxxxxxxxx] On 
> Behalf Of Gomes, Chuck
> Sent: Thursday, June 13, 2013 11:39 AM
> To: Brian Peck; GNSO IGO INGO
> Subject: [gnso-igo-ingo] RE: Proposed Public Comment Period for Initial Report
>  
> I don’t strongly object to this but do want to express some concerns.  
> Considering that a lot of groups tend to submit their comments on the last 
> few days of the comment period, it seems to me that ending the comment period 
> on the 15th, the 2nd official day of the Durban meetings and the third day of 
> meetings for many GNSO participants might present some challenges.  Also, it 
> would not allow much time for review of the initial comments before our WG 
> meeting in Durban.  I personally think that a better solution would be to 
> leave the initial comment period at 21 days and extend the reply period by 7 
> days.
>  
> I understand that in reality there is not a lot of practical difference 
> between the initial and reply comment periods so my concerns are mitigated by 
> that fact.  In the case of the RySG, I think that we should be able to submit 
> our initial comments in advance of travel dates, which will start on the 10th 
> or earlier for some because of the very long travel time, so as David already 
> said, I am sure that the RySG can live with the proposed plan.  If other SGs 
> and constituencies feel the same way, then I would go with the proposal.
>  
> Chuck
>  
> From:owner-gnso-igo-ingo@xxxxxxxxx [mailto:owner-gnso-igo-ingo@xxxxxxxxx] On 
> Behalf Of Brian Peck
> Sent: Thursday, June 13, 2013 11:11 AM
> To: GNSO IGO INGO
> Subject: [gnso-igo-ingo] FW: Proposed Public Comment Period for Initial Report
>  
> Dear WG Members,
>  
> We are planning to publish the Initial Report for public comment tomorrow, 14 
> June and wanted to provide you with the proposed public comment and reply 
> periods.  Taking into consideration that the PDP WG Charter mandates the WG 
> to fulfill the requirements of the PDP "in an expedited manner," while also 
> recognizing that under the minimum 21 day requirements for the public comment 
> period and reply period each, the reply period would be open between 6 July 
> and 26 July during which the Durban Meeting will take place, after consulting 
> with Thomas as Chair, we are proposing the following timeframes:
>  
> Extend the public comment period by 9 days to provide a 30 day period, 
> starting 14 June and ending at 23:59 on Sunday, 14 July
> Maintain the 21 day period for the reply period, starting 15 July and ending 
> at 23:59 on Sunday, 4 August.
>  
> By extending the public comment period this would provide as much time as 
> possible prior to the starting date of the Durban Meeting (instead of the 21 
> day period ending on 5 July), while also pushing back the reply period 
> deadline by nine days to provide extra time after the Durban meeting.  We 
> realize that the timing of this public forum during the Durban Meeting is not 
> the most optimal, but given the Charter mandate we hope you agree that this 
> is a workable solution.  
>  
> As we would like to publish the report tomorrow please advise if there are 
> any strong objections as soon as possible but no later than tomorrow, Friday 
> 14 June at 12:00 UTC  – otherwise we will go with this schedule.  Thank you 
> very much for your continued support and contributions to the WG.
>  
> Best Regards,
>  
> Brian
>  
> Brian Peck
> Policy Director
> ICANN 
>  
>  
> 
>  
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