AFNIC comment on the updated Supplementary Procedures for IRP

[Marianne Georgelin <marianne.georgelin@xxxxxxxx>]

Afnic is a registry operator for top-level domains corresponding to the 
national territory of France (.fr, .re, .pm, .yt, .wf, .tf). and is also the 
backend registry operator for 15 new generic Top Level Domains. Afnic is a 
member of CCNSO, Centr, and APTLD. 



We welcome this opportunity to share our views on the Supplementary Procedures 
for IRP through this public comment and to acknowledge the efforts being 
undertaken by the IRP IOT in updating those rules. 



We support the comments made by Spain and Swistzerland (through their GAC 
Representatives) on the necessity to enhance diversity and to warrant a 
level-playing field in the process (with reference to Section 4.3 (l) and 
Section 4.3 (j) (iv) of the Bylaws). We agree with their proposal to add to the 
Supplementary Procedures the appropriate measures to ensure translation and 
interpretation at no charge during the hearings when requested by the claimant. 



The procedures should also ensure that parties with less structured legal 
ressources have enough time to introduce their claims within the time limit set 
forth for the procedure. We believe that the proposed 45 days time limit is too 
short to achieve this goal and we therefore agree with the comments supporting 
its extension to a 6 month period. 

Thank you. 









Marianne GEORGELIN 
Responsable des Politiques de Registre 
Senior Policy Manager 


marianne.georgelin@xxxxxxxx 
Mob +33 (0) 6 30 15 19 09 

Tel +33 (0) 1 39 30 83 09 
Skype / m.georgelin