[IOT] Disclosure of interest

Mike Rodenbaugh mike at rodenbaugh.com
Sat Dec 12 01:26:29 UTC 2020

I want to notify the group that I have filed a complaint in California
Superior Court on behalf of several applicants for the .hotel gTLD.  As
stated in the attached Complaint, our clients once again request that ICANN
provide them with critical procedural rights guaranteed by the ICANN
Bylaws, including independent review of their Requests for Reconsideration
by an Ombudsman, an Independent Review Process provided by a specially
trained Standing Panel with capability for *en banc* review of any appeal,
and all administrative costs paid by ICANN.

I had already disclosed my representation in an IRP raising those same
claims, among others, which is still pending.  We have asked ICANN to stay
that proceeding before panel selection, until such time as the Superior
Court resolves our Complaint.

I am happy to answer any questions, if any.


[image: Logo]

Mike Rodenbaugh


548 Market Street, Box 55819

San Francisco, CA 94104


mike at rodenbaugh.com


+1 (415) 738-8087
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