Re: [gnso-vi-feb10] Revised SRSU text

[Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>]

Kristina,

Comments on the SRSU text. The form is call and response.

Eric

Page 1, Para 1, sentence 3:
"Within the VI Working Group, there was a general endorsement of the 
idea of an SRSU exception."
I suggest qualifying this by observing that advocates for policy 
choices other than broad continuity included an SRSU exception, 
explicit in proposals which otherwise contained conditional 
cross-ownership language, and implicit in proposals which removed 
cross-ownership restriction, and that in the Brussels meeting period, 
when compromises were attempted, a limited exception to Recommendation 
19 was offered by the advocates for broad policy continuity.
I know it is a lot more words and takes away from the punch of the 
claim, but it could be more useful to show which policy advocates 
found common cause with the committed SRSU policy advocates.
Para 2, sentence 2:
"... that satisfied additional criteria intended to limit the 
applicability of the exceptions and to discourage abuse and gaming of 
the exceptions."
This is advocacy. Please consider cutting it.

Para 2, Types of SRSU exceptions, sentence 3:
"Several WG participants who are members of the Non-Commercial 
Stakeholders Group proposed an SRSU exception for non-governmental 
organization registries (NGOs) (referred to as .ngo registry) ..."
I have no issue with calling attention to the SG affiliation of any 
advocate, but implicit in this is something false. The previous 
sentence has the IPC as a body making a proposal based upon real 
self-interest. This sentence elevates the association of these WG 
participants who are members of the NC SG as advocates for NGOs as 
recipients of a broad cross-ownership and/or Recommendation 19 
exception, and implicitly their interests, to the same level as the 
IPC and its membership of brand owners.
This association is false unless there are one or more NGOs which 
authorized these NC SG members to act on their behalf, as brand owners 
have authorized their IPC SG members, to pursue indistinguishable ends.
Has any NGO asked for an exception? The Red Cross contacted CORE and 
it did not, to the best of my knowledge, ask for a SRSU exception. It 
asked for a fraud solution and brand protection application, which is 
not a registration policy so narrow as to admit only one registrant.
We are not talking about the interests of imaginary brands. We are not 
allowing random people to claim "they speak for XYZ Corp and its 
portfolio of brands". We should not entertain claims so conjectural as 
a claim that some VI WG volunteer may appropriate the good name of 
some public interest entity to advance claims that lack any other basis.
The requirement that a policy advocate represents an actual applicant 
is something that can't be satisfied now, it has to have been 
demonstrable when the policy was first advocated.
Para 2, Types of SRSU exceptions, sentence 4.

Please consider cutting this. If you and I, who've both been watching 
this issue like hawks, can't think of the reason, it isn't enough to 
add to the word count.
Page 2, para 1, sentence 1:

This is advocacy. Please consider cutting it.

Para 1, sentence 2:

This is advocacy. Please consider cutting it.

Para 1, sentence 3:

This is policy. Please don't cut it.

End.