[IOT] IOT - Material on timing issue

Bernard Turcotte turcotte.bernard at gmail.com
Mon Sep 21 21:08:16 UTC 2020


Please find attached 3 documents which summarize the situation on the Time
To File issue up to and including the results of the public consultation on
this specific topic.

The first document is the announcement for the public consultation on the
Time To File issue (the second IOT public consultation) and lays out the
changes that were proposed following the initial consultation on the
revised rules (held in late 2016). This summarizes the situation which led
to the proposed changes as well as those proposed changes.

The second and third documents are spreadsheets that present the comments
made on timing issues in the first and second public consultations.

The Announcement summarizes the results of the first public consultation.

The summary of the second public consultation is as follows:

   - 100% in favour of changing 45 to 120 days (but with many saying that
   it should be more than 120 days).
   - Majority in favour of removing the 1-year repose. (6 in favour, 2
   - Many noted that the time from when the 120 days starts needs to be
   clarified vs other applicable mechanisms to a dispute (such Reconsideration
   etc )
   - Several noted that the definition of “ought reasonably to have been
   aware,” was too vague (NTIA comment).

Following the second public consultation, the IOT did not return to this
issue as it was focusing on producing the Interim Rules which were accepted
by the ICANN Board but these did not include the proposed changes to the
Time to File issue which was the core of the second public consultation.

Bernard Turcotte
ICANN Support to the IOT


Susan Payne
Chair IOT
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