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

["Gomes, Chuck" <cgomes@xxxxxxxxxxxx>]

I don't think the concern is so much about having comment periods run during 
ICANN meetings as it is about the fact that during ICANN meetings including 
associated travel time many people have little or no time to spend on comments. 
 The main point as I recall was to make sure that the length of comment periods 
was extended when they overlap with ICANN meetings; otherwise, the period is 
effectively cut short for those who are involved in the meetings.

In the case of the Durban meeting, for many of us, extending the initial 
comment period  from July 10 to 15 doesn't add any value for a couple reasons: 
1) we are traveling and/or too busy in meetings to spend any time on public 
comments; 2) for groups that need to get support for comments from there 
members, it is extremely hard to do because so many people are traveling or 
busy in meetings.  If we are going to extend the initial comment period into 
the ICANN meetings, then we should do it until the 17th; then SGs and 
constituencies could at least use constituency day to finalize their comments 
and determine level of support.

Chuck

From: owner-gnso-igo-ingo@xxxxxxxxx [mailto:owner-gnso-igo-ingo@xxxxxxxxx] On 
Behalf Of Thomas Rickert
Sent: Thursday, June 13, 2013 12:22 PM
To: Mary.Wong@xxxxxxxxxxx
Cc: GNSO IGO INGO
Subject: Re: [gnso-igo-ingo] RE: Proposed Public Comment Period for Initial 
Report

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<mailto: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<mailto:mary.wong@xxxxxxxxxxx>
Phone: 1-603-513-5143
Webpage: http://www.law.unh.edu/marywong/index.php 
<http://www.law.unh.edu/marywong/index.php%0d%0a>


>>>
From:

"Shatan, Gregory S." <GShatan@xxxxxxxxxxxxx<mailto:GShatan@xxxxxxxxxxxxx>>

To:

"'Gomes, Chuck'" <cgomes@xxxxxxxxxxxx<mailto:cgomes@xxxxxxxxxxxx>>, Brian Peck 
<brian.peck@xxxxxxxxx<mailto:brian.peck@xxxxxxxxx>>, GNSO IGO INGO 
<gnso-igo-ingo@xxxxxxxxx<mailto: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> 
[mailto:owner-gnso-igo-ingo@xxxxxxxxx<mailto: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> 
[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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