[Ws2-jurisdiction] Jurisdiction Draft 11 11 Feb 2018

[Kavouss Arasteh]

 Dear Greg,
Thank You very much for the draft
I was unable to attend the last meeting as I was on the Plane However, on
page 16 .Section/ Paragraph 4,I have noted a paragraph in bold.
The inclusion of that  bolded paragraph, has a negative connotation as it
negate and neutralize the action(s) described / required in that paragraph.
I therefore suggest the following amendment which convey the same message
but in positive sense
See Below
* ” 4. Application Process.*
Applicant acknowledges that ICANN must comply with all U.S. laws, rules,
and regulations. One such set of regulations is the economic and trade
sanctions program administered by the Office of Foreign Assets Control
("OFAC") of the U.S. Department of the Treasury. These sanctions have been
imposed on certain countries, as well as individuals and entities that
appear on OFAC's List of Specially Designated Nationals and Blocked Persons
(the "SDN List"). ICANN is prohibited from providing most goods or services
to residents of sanctioned countries or their governmental entities or to
SDNs without an applicable U.S. government authorization or
exemption. ICANN generally will not seek a license to provide goods or
services to an individual or entity on the SDN List. In the past, when
ICANN has been requested to provide services to individuals or entities
that are not SDNs, but are residents of sanctioned countries, ICANN has
sought and been granted licenses as required.   While ICANN ,in
principle, is under no obligations to seek such licenses and, in any given
case,  and  OFAC may decide not to issue a requested license, nevertheless
ICANN, is required to apply for and use reasonable best efforts to secure
an OFAC license if the other party is otherwise acceptable as a registrar
(and is not on the SDN List).  During the licensing process, ICANN should
be helpful and transparent with regard to the licensing process and ICANN’s
efforts, including ongoing communication with the potential registrar.
Moreover, I saw that you referring to the comments from Non Commerciale
Stakeholder  that you want  to consider for which I have no objection but,
Why you have not taken into account comments from Russia, Italy, France
into account
It seems you have totally ignore  these  comments that formally requested
you to briefly refer to the French, Italian, Russian comments in the
introductory part
Regards .
Kavouss
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