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Seven Business Day comment period for IRT Draft Report is unacceptable

  • To: irtp-draft-report@xxxxxxxxx
  • Subject: Seven Business Day comment period for IRT Draft Report is unacceptable
  • From: George Kirikos <gkirikos@xxxxxxxxx>
  • Date: Sat, 25 Apr 2009 09:48:59 -0700 (PDT)

We object to the extremely short comment period for this report, and the method 
by which it was drafted.

It was released at the end of the day on April 24, 2009 (a Friday) We are told 
that "those wishing to have the IRT consider their comments in connection with 
its final report should submit comments by 6 May, 2009." Given that May 1st is 
a holiday in a large number of countries, this leaves many people with only 7 
(seven) or at best 8 (eight) business days in which to read the report, consult 
with colleagues, and write a coherent response to a lengthy document.

Given the IRT's extreme lack of transparency and its very narrow representation 
of interests (i.e. it was not an open GNSO workgroup or task force where any 
stakeholder could join; there was no public mailing list archive or MP3 
recordings/transcripts of meetings), it is unclear whether any responses 
submitted by the May 6 deadline will even be considered, especially given that 
detailed comments and recommendations made to the DAG v1 and v2 reports did not 
receive any apparent consideration by the committee in this draft report. There 
is no public audit-trail of any discussions leading up to this report, but it 
instead appears to be a rehashing of certain "wish list" items by a narrow few 
in the community, instead of a balanced proposal representative of all 

The IRT is working within artificial deadlines imposed by the ICANN Board in 
its March 6th resolution. We recommend that the IRT go back to the Board to 
advocate that these artificial deadlines need to be rethought. Given the 
comments overwhelmingly opposed to new gTLDs both in the first and second 
versions of the DAG (with the 2nd comment period ending only last week), ICANN 
has not justified that the gTLD program should go forward in any form, and not 
justified the colossal misuse of time that could be better spent on important 
issues such as DNSSEC, IPv6 and IDN ccTLDs, and fixing problems in existing 
gTLDs. It is our hope that the NTIA/DOC/DOJ will provide ICANN with far clearer 
and direct guidance in this regard, as it is clear to us that certain minority 
interests have captured the agenda at ICANN and are setting its plans to the 
detriment of the public.

There is no "pressing need" that a final report be delivered by May 24, 2009, 
especially given that the Sydney meeting begins on June 21, 2009. A rushed job 
will not lead to a solution that has consensus support, and forming consensus 
is ICANN's mission. If a consensus cannot be reached, ICANN has to realize that 
the matter might be a threshold issue that must lead to continued study and 
work, rather than proceeding with half-baked solutions over the objections of a 
large number of stakeholders.

We note the comment period for version 1 of the DAG closed on January 7, 2009 
(after 76 days), and allowed for translation into multiple languages before the 
end of the comment period. Analysis and summary of those comments by ICANN 
staff were released to the public on February 18, 2009, namely 42 days later 
(at which time version 2 of the DAG was also released). We would expect the 
IRT, if it's to even have a remote possibility of reaching a global consensus, 
would need similar time periods. At a minimum, the time periods should be 
shifted so that public comments are due 2 weeks before Sydney, with analysis of 
those comments to be released just before Sydney, and discussion to take place 
during Sydney. A final report would then be released a few weeks after Sydney, 
with a further comment period on that final report.

In conclusion, we look forward to the IRT's realization that the current 
schedule is needlessly rushed, and requires adjustment. We expect that the IRT 
will make in the immediate future a clarifying announcement with a reasonable 
time frame for comments if it expects to maintain the goodwill of the community 
in its ongoing efforts to reach a consensus. We also expect that they will 
positively respond to the request for public archives of mailing lists and MP3 
recordings/transcripts in order to improve transparency.


George Kirikos
Leap of Faith Financial Services Inc.

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