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RE: [gnso-irtp-b-jun09] RE: For review - IRTP Part B Public Comment Announcement

  • To: "Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>, "James M. Bladel" <jbladel@xxxxxxxxxxx>
  • Subject: RE: [gnso-irtp-b-jun09] RE: For review - IRTP Part B Public Comment Announcement
  • From: "Erdman, Kevin R." <Kevin.Erdman@xxxxxxxxxx>
  • Date: Wed, 2 Sep 2009 12:25:55 -0400


I think it would be worth considering who are the "real public," and how to
solicit their comments.  Typically, public comment periods are not used by
ordinary citizens but rather by the stakeholders most affected by the issues
involved with the subject matter of the public comment.  In this case, are
the domain owners the relevant stakeholders?  Are the registries the relevant

In fairness to my colleagues at Pinsent Masons, publishers of Out-law.com,
they are fully aware of the ICANN process and explain it fairly well in the
full article (http://www.out-law.com/page-10328) even if the headline may be
a bit misleading.

Assuming that domain holders are the relevant stakeholders, would the
following be a suitable introduction?

"The ruling body of ICANN relating to Domain Names (the Generic Names
Supporting Organization, or GNSO) is asking for public comments on issues
relating to procedures for modifying registration information and
transferring domain names between registers.  Specifically, comments on
establishing a new urgent return procedure for challenging potentially
fraudulent or inappropriate domain name transfers or alterations, and other
procedures for preventing inappropriate or fraudulent changes in domain name
registrations, are requested from the domain name owning public.  The details
of the issues being considered is provided below:"
Kevin R Erdman  T: 317.237.1029 | F: 317.237.8521 | C: 317.289.3934
Intellectual Property, Internet, and Information Attorney, Registered Patent

-----Original Message-----
From: owner-gnso-irtp-b-jun09@xxxxxxxxx
[mailto:owner-gnso-irtp-b-jun09@xxxxxxxxx] On Behalf Of Michele Neylon ::
Sent: Wednesday, September 02, 2009 11:00 AM
To: James M. Bladel
Cc: Marika Konings; Gnso-irtp-b-jun09@xxxxxxxxx
Subject: RE: [gnso-irtp-b-jun09] RE: For review - IRTP Part B Public Comment


With all due respect while including a link to a glossary may help it doesn't
really address the core issue. It merely sidesteps it.

While a "call for comments" may need to use precise technical and / or legal
terminology and jargon in its body, I strongly feel that a more accessible
introductory text may go a long way to helping us, as a group, get input from
the real public.

In English speaking countries we read the text from left to right and from
top to bottom. So we will not, in general, read beyond the first few lines if
we aren't obligated to do so. 

For example, only last week Out-law.com published an article entitled: "ICANN
may help owners recover domain names after expiry". Anyone reading that title
would assume that ICANN was going to be doing something in that area, whereas
it actually referred to another public comment period. So how did a
publication like Out-law.com end up with that perception? Presumably they
only had access to the information on the ICANN website and more specifically
the call for comments as published there (for the PEDNR WG). 



Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Brand Protection
Intl. +353 (0) 59  9183072
Locall: 1850 929 929
Direct Dial: +353 (0)59 9183090
Fax. +353 (0) 1 4811 763
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland  Company No.: 370845


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