RE: [gnso-irtp-b-jun09] RE: For review - IRTP Part B Public Comment Announcement
Michele, 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 stakeholders? 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 Attorney BAKER & DANIELS LLP WWW.BAKERDANIELS.COM 300 N. MERIDIAN STREET, SUITE 2700 | INDIANAPOLIS, IN 46204 -----Original Message----- From: owner-gnso-irtp-b-jun09@xxxxxxxxx [mailto:owner-gnso-irtp-b-jun09@xxxxxxxxx] On Behalf Of Michele Neylon :: Blacknight 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 Announcement James 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). Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting & Colocation, Brand Protection http://www.blacknight.com/ http://blog.blacknight.com/ http://mneylon.tel/ 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 ---------------------------- ATTENTION: To ensure compliance with applicable Internal Revenue Service Regulations, we inform you that any tax advice contained in this electronic message was not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code. This message and all its attachments are PRIVATE and may contain information that is CONFIDENTIAL and PRIVILEGED. If you received this message in error, please notify the sender by reply e-mail and delete the message immediately.