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

[Alan Greenberg <alan.greenberg@xxxxxxxxx>]

A couple of points:

- it makes no sense to have the comment period 
end on one day and the reply period start many 
days later. Just extend the reply period. 
Otherwise you are saying that for the gap one 
could not send a message to that e-mail address???
- I can support the proposed timings, but I think 
that it makes a LOT more sense to extend the 
comment period by 2 more days and give people an 
opportunity to finalize and approve their 
comments on Constituency Day (Tuesday). Then 
start the 21 day reply. That will likely maximize 
the SUBSTANTIVE comments, and that, after all, is 
what we are trying to do. And it only adds 2 days to the proposal.
Alan

At 13/06/2013 12:48 PM, Gomes, Chuck wrote:
> 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 
> <<mailto:Mary.Wong@xxxxxxxxxxx>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: <mailto:mary.wong@xxxxxxxxxxx>mary.wong@xxxxxxxxxxx
> Phone: 1-603-513-5143
> Webpage: 
> <http://www.law.unh.edu/marywong/index.php%0d%0a>http://www.law.unh.edu/marywong/index.php 
>
>
> >>>
> From:
> "Shatan, Gregory S." <<mailto:GShatan@xxxxxxxxxxxxx>GShatan@xxxxxxxxxxxxx>
> To:
> "'Gomes, Chuck'" 
> <<mailto:cgomes@xxxxxxxxxxxx>cgomes@xxxxxxxxxxxx>, 
> Brian Peck 
> <<mailto:brian.peck@xxxxxxxxx>brian.peck@xxxxxxxxx>, 
> GNSO IGO INGO <<mailto:gnso-igo-ingo@xxxxxxxxx>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: 
> <mailto:owner-gnso-igo-ingo@xxxxxxxxx>owner-gnso-igo-ingo@xxxxxxxxx 
> [mailto:owner-<mailto:gnso-igo-ingo@xxxxxxxxx>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:<mailto:owner-gnso-igo-ingo@xxxxxxxxx>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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