[IOT] Revised language for seeking public comment on Rule #4, time-for-filing

[McAuley, David]

Dear members of the IRP IOT:



As discussed on our teleconference of May 24, I have tried to redraft a portion of the language I suggested for public comment regarding Rule #4, Time-for-Filing.



In my email<https://mm.icann.org/pipermail/iot/2018-May/000397.html> of May 22, I suggested certain language for this request for public comment. One sentence of that email was as follows:



It appeared to the IRP IOT that while there was qualified support expressed for this kind of time limitation, there was more criticism of it as unfair and unduly restrictive.



In an email<https://mm.icann.org/pipermail/iot/2018-May/000398.html> on the same day, Malcolm expressed concern with that sentence.



On our teleconference of May 24, we agreed to take a more straight-forward approach, and I was to suggest language to that end. Here is what I suggest:



1.      That in using the language I suggested in my email of the 22nd, we delete the sentence above shown in yellow.



2.      That we replace that sentence with the following language shown here in bold:



On the topic of the 12-month limitation to file an IRP, 13 of the 19 respondents to the public consultation commented on this with 11 ​having issues with this proposal and either opposed it or proposed changes.



On the topic of the 45-day aspect of the Time-for-Filing language, 11 of the 19 respondents commented on this portion of the draft and all 11 had issues with this proposal and either opposed it or proposed changes.



All material and comments relating to the public consultation on the IRP held in late 2016 is archived at https://www.icann.org/public-comments/irp-supp-procedures-2016-11-28-en



Please comment on list and we can hopefully wrap this language up on list or on next call.



Best regards,

David



David McAuley

Sr International Policy & Business Development Manager

Verisign Inc.

703-948-4154



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