[bc-gnso] FW: Respectfully Requesting An Extension of the Comment Deadline

[Phil Corwin]

FYI, I just filed the comment below on ICA's behalf ---





The domain name registrants, investors and developers represented by the Internet Commerce Association (ICA) wish to respectfully request that ICANN extend the comment period on the proposed Final gTLD Applicant  Guidebook (AG) by a minimum of two weeks (14 days) and preferably by an additional three weeks.



The 28 days allowed for comment on this AG is just over half the average time (50 days) allotted for comment on the four prior iterations of the Guidebook; a 2-3 week extension would bring the length of the comment period in line with that provided for prior versions. This fifth version of the AG does not just contain proposed resolutions of previously discussed matters but significant new material that we are working to assimilate and understand. Many ICA members are present in Cartagena and busy attending sessions and interfacing with staff in this attempt, but meaningful participation at the Cartagena meetings mitigates against preparation of a fully informed comment letter for consideration by our membership prior to its submission in just under four days.



The reasonable extension we are requesting should in no way interfere with approval of a Final AG by the ICANN Board that permits opening of the application window for new gTLDs in Spring 2011. We certainly hope that the December 10th comment deadline has not been set in order to facilitate such a vote by the Board in Cartagena. The current comment deadline will occur just hours before the start of the Board Meeting in Columbia, and given the time and work burdens placed on key ICANN staff by this meeting there is no way they can review and meaningfully summarize suggestions and concerns expressed in the final round of comments (most of which are usually submitted within the final 24 hours of any comment period) to aid the Board in understanding them prior to a final vote. Given recent expressions of concern by the GAC and individual national governments regarding ICANN's policy process, and particularly the adequacy of explanations of policy decisions, it is particularly important that the Board vote on the Final AG be conducted in a manner that demonstrates that all submitted comments have been accorded serious consideration.



We appreciate your consideration of our suggestion on this matter.



Sincerely,

Philip S. Corwin

Counsel

Internet Commerce Association



Philip S. Corwin
Partner
Butera & Andrews
1301 Pennsylvania Ave., NW
Suite 500
Washington, DC 20004

202-347-6875 (office)

202-347-6876 (fax)

202-255-6172 (cell)

"Luck is the residue of design." -- Branch Rickey
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