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

[<Mary.Wong@xxxxxxxxxxx>]

Sure, I was just hoping to avoid the sort of complaint we'd heard
before, about people needing to scramble to send in comments while an
ICANN meeting is going on. I support extending the initial comment till
the end of the Durban meeting, then starting the reply period. 

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:  
Alan Greenberg <alan.greenberg@xxxxxxxxx> 

To: 
"Gomes, Chuck" <cgomes@xxxxxxxxxxxx>, Thomas Rickert
<rickert@xxxxxxxxxxx>, "Mary.Wong@xxxxxxxxxxx" <Mary.Wong@xxxxxxxxxxx> 

CC: 
GNSO IGO INGO <gnso-igo-ingo@xxxxxxxxx> 

Date:  
6/13/2013 1:45 PM 

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

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 <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  (
http://www.law.unh.edu/marywong/index.php%0d%0a )


>>>
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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