[Ccwg-auctionproceeds] Judith Hellerstein's comments on the Auction Proceeds Draft

[Maureen Hilyard]

Hi Anne

>From among your interesting email, I have selected one section which is
what I have frequently proposed to our At-Large team and been told that it
would not be possible - but there surely MUST be an alternative available
to ICANN if we were to use Mechanism A that would allow ICANN to establish
an independent body but in association with them somehow.  I too asked if
we could seek more advice on what might be possible. I mentioned the PTI
structure not because of what it does, but that it was a separate
autonomous structure set up for a completely specific purpose that is
nothing to do with ICANN's day to day work. This new mechanism that I was
hoping we might get some legal feedback on, could be similar and its link
with ICANN would be the auction funds that would be transferred to it from
ICANN each year or whenever. A trust would work.  I think it should still
be considered.

*Regarding Option A, it seems to me that some California legal advice on
the best way to effectively preserve the necessary independence would be
appropriate.  It may be advisable for ICANN to set up a charitable trust
and to name Trustees who again, constitute a voting majority which is
independent of ICANN staff and Board.  The Trustees would then have their
own fiduciary duty to the Trust itself (which would encompass the ICANN
mission but would not owe a fiduciary duty to ICANN the corporation.)  *

*Maureen*


On Fri, Jul 26, 2019 at 12:03 PM Alan Greenberg <alan.greenberg at mcgill.ca>
wrote:

> Several people have alluded to ICANN using some of the auction funds to
> boost the reserve and have used this as the reason why we need a separate
> entity. My recollection is that very early on, the Board made it clear that
> regardless of the mechanism, they did not foresee transferring all of the
> money (whether it is $100m or $235m) in one fell swoop. I believe the term
> "tranche" was use to say that the monet would be transferred as needed, and
> that ICANN would still maintain full control of the remaining funds. And
> ultimately if the situation warranted might redirect them (the latter part
> is my words, not something said by the Board).
>
> Alan
>
> At 26/07/2019 05:17 PM, Aikman-Scalese, Anne wrote:
>
> Hi all,
>
> I am writing these comments with hopes that Marilyn will post to the CCWB
> Auction Proceeds list.
>
> To further demonstrate this principle regarding the need for independence,
> I will mention that in connection with the presentation of the staffing
> “readiness†plan for Subsequent Procedures that was drawn up by ICANN
> staff, the Marrakech presentation to the Sub Pro WG included a comment from
> an ICANN officer that among the possible sources of funding for staffing up
> for the next round might be to “borrow from Auction Proceeds†.  (If you
> don’t believe me, check the Sub Pro recording from that session in
> Marrakech.)
>
> I believe I had commented remotely in Marrakech that to the extent that
> decisions on hiring and firing of grant-making personnel would be made by
> ICANN staff and/or the Board, there could not possibly be a reasonable
> level of independence in the grant-making operation and it would be
> extremely difficult for ICANN to defend challenges to grants made by that
> department.  Auction proceeds are already a controversial topic and it
> would be a mistake to cause that topic to become more controversial by
> simply setting up some department guidelines and expecting people who are
> hired and fired by ICANN Org and/or Board to do anything other than what
> they are directed to do by those who control their paycheck.
>
> The old saying goes that “There is nothing new under the sun.â€
> Although we like to think that ICANN’s decision-making processes are
> entirely different from other entities, the management and risk management
> challenges associated with this task and the related ethical concerns have
> been faced by many institutions.  One notable point of comparison would be
> universities, which generally have a number of associated entities involved
> in furthering their missions and which, like ICANN, operate in an
> environment where public trust and confidence is key.
>
> Regarding Alan’s comment about the composition of a Board in relation to
> Option C, I agree it’s clear that PTI is essentially controlled by
> ICANN.  However, the non-profit corporation’s By-Laws could easily
> provide that the majority of directors NOT be affiliated with ICANN.  This
> would ensure independent operation in accordance with the Foundation’s
> Articles and ByLaws as long as the Foundation’s staff was not hired and
> fired by ICANN Org staff or the ICANN Board.
>
> Regarding Option A, it seems to me that some California legal advice on
> the best way to effectively preserve the necessary independence would be
> appropriate.  It may be advisable for ICANN to set up a charitable trust
> and to name Trustees who again, constitute a voting majority which is
> independent of ICANN staff and Board.  The Trustees would then have their
> own fiduciary duty to the Trust itself (which would encompass the ICANN
> mission but would not owe a fiduciary duty to ICANN the corporation.)  In
> this regard, one piece of the analysis relating to Option A that is clearly
> missing is the fact that each of the ICANN Directors HAS A FIDUCIARY DUTY
> TO THE ICANN CORPORATION ITSELF.  This fiduciary duty to the ICANN
> corporation can easily be in conflict with the goals and purpose of the
> grant-making.  For example,  for the ICANN Board, the fiscal condition of
> the corporation itself is paramount.   If we put ICANN Directors in the
> position of having to review the actions of the grant-making organization
> while at the same time allowing the corporation itself to go “under†,
> we are asking too much.  The only safe way to deal with this potential
> conflict is to assure total independence of grant-making and many of the
> public comments reflect this major concern.
>
> The above considerations are not terribly different from the governance
> issues faced by universities and the foundations that support their
> mission.  Certainly Option C,  a separate non-profit corporation with
> majority independent directors would be preferable from the standpoint of
> public awareness and accountability.  If that mechanism is seen as too
> unwieldy, ICANN should, at a minimum, set up a Trust mechanism to hold the
> funds and appoint majority independent Trustees on the Board of Trustees.
> These Trustees should be responsible for hiring and firing qualified
> grant-making personnel and the Trust operations should be independent even
> if housed in the same building.  Best practices would dictate against
> sharing personnel.  And yes, the Trust would need its own operating budget.
>
> If the CCWG has already examined the Trust mechanism in the context of
> Option A, I apologize for bring this up.  It’s just completely
> unrealistic to think that you can establish the required independence by
> setting up a department within ICANN where employees responsible for
> grant-making are hired and fired by ICANN staff and/or Board.
>
> Anne
>
>
> *Anne E. Aikman-Scalese *Of Counsel
> 520.629.4428 office
> 520.622.3088 fax
> AAikman at lrrc.com
> _____________________________
> [image: []]
> Lewis Roca Rothgerber Christie LLP
> One South Church Avenue, Suite 700
> Tucson, Arizona 85701-1611
> lrrc.com
>
>
>
>
>
> *From:* Marilyn Cade <marilynscade at hotmail.com>
> *Sent:* Friday, July 26, 2019 2:09 PM
> *To:* Elliot Noss <enoss at tucows.com>; Alan Greenberg <
> alan.greenberg at mcgill.ca>
> *Cc:* Vanda Scartezini <vanda at scartezini.org>;
> ccwg-auctionproceeds at icann.org; Aikman-Scalese, Anne <AAikman at lrrc.com>
> *Subject:* Re: [Ccwg-auctionproceeds] Judith Hellerstein's comments on
> the Auction Proceeds Draft
>
>
> *[EXTERNAL] ------------------------------ *
>
> folks, we must avoid being about ourselves. We need fact based information
> that is not our own experience, which will always be influenced by our own
> experiences. I am not being critical. I am merely thinking of my mentoring
> professor who was trained by Sal Alenski. We all have opinions from
> experiences of our own. They are small and if we are independent thinkers,
> then we are required to think not about what we experienced, but what is
> "known" and documented.
>
> Let's not assume anything from our own experience. Count on facts.
>
> from others and then inform us. That was my message. We have been a bit
> too much opinion based in my view. Not everyone need agree with that.
> BUT, we had only a few advisory discussions with a young and ICANN
> selected expert, who then disappeared, and didn't have all the expertise we
> asked for in some of our questions. And we haven't even had that "expert"
> to query in many months.
>
> We are charged with being non biased; informed/ demanding factual
> information. Let's focus on whether we can deliver on that, at least on two
> options.
>
> And ask ourselves [and require ICANN to fund any needed independent, and
> totally unbiased views] quickly.
>
> ICANN has a lot of $$ tied up in their own "risk" in the event that they
> fall over, right? we even agreed to a contribution to that fund from the
> Auction Proceeds at a limited, and one time contribution.
>
> We don't want the mechanism we create to be vulnerable to more liability
> for ICANN, to Board or new /CEO/senior staff changes in perspective.
>
> This is external to ICANN's core mission, but needs to be consistent with
> ICANN's overall mission.
>
> I keep looking at attendance of all of us; I read all transcripts, when
> not able to attend. I read all the transcripts from the beginning before
> accepting he CSG membership role after meeting 17.
>
> Time to present two options. One and three.
>
> Facts are our friends.
>
>
>
>
>
> ------------------------------
> *From:* Elliot Noss <enoss at tucows.com>
> *Sent:* Friday, July 26, 2019 3:33 PM
> *To:* Alan Greenberg <alan.greenberg at mcgill.ca >
> *Cc:* Vanda Scartezini <vanda at scartezini.org>; Marilyn Cade <
> marilynscade at hotmail.com >; ccwg-auctionproceeds at icann.org <
> ccwg-auctionproceeds at icann.org>; Aikman-Scalese, Anne <AAikman at lrrc.com>
> *Subject:* Re: [Ccwg-auctionproceeds] Judith Hellerstein's comments on
> the Auction Proceeds Draft
>
> Hi Alan,
>
> I think (but could be wrong) that Vanda was agreeing with you and showing
> Marilyn a working example of A.
>
> EN
>
>
> On Jul 26, 2019, at 12:55 PM, Alan Greenberg <alan.greenberg at mcgill.ca >
> wrote:
>
> Vanda, if i correctly understood you, some of your projects were sent out
> to existing organizations for management but that is not what we are
> discussing here (that is closer to Mech D which we have discarded). We are
> talking about first having to build then run the external organization
> (foundation).
>
> Alan
> --
> Sent from my mobile. Please excuse brevity and typos.
>
> On July 26, 2019 12:13:15 PM EDT, Vanda Scartezini <vanda at scartezini.org>
> wrote:
> Dear friends
>
> As Marilyn would like to hear some fact base, below just to share my own
> experience :
> I was responsible (besides other things) during my time in the
> government,  for some grants  ( the amount was not small, around 500
> millions USD a year) to select relevant projects under the Information
> Technology Law under the Federal Secretariat as was the head of.
> We were public, could not contract anyone, and should be accountable to
> the federal Government, Treasure and IR ( since the money was from fiscal
> incentives from companies) the Public Ministry ( from Judiciary) and the
> Account Tribunal which controls the righteous expenditure of public organs.
> To deal with this challenge we form a Committee  of volunteers , without
> paying any member.
>  Processes to receive, analyze, select and specially control the
> disbursement of grants demands a lot of work , people without conflict  and
> with a clear knowledge of the theme associated to the grant to allow a fair
> and constructive selection of the projects.  The committee had a maximum of
> 5% of the total $$ to do this job.
> The money were for staff support, legal support, travels to visit the
> proposed groups for any project, general costs as meals etc.  registered
> and published detailed to be accountable to all.
>  How we have worked:
> We announced the openness of the slot of time to receive proposals – 3
> months –  and publish the requisitestes and documentation demanded as
> historical, previous grants etc as well general criteria we will use for
> selection under the Law.  Took us  2 previous months to prepare the public
> call then we start our job while receiving all projects -  we made a pre
> selection into 3 categories- excellent / good / poor  and then analyze
> overall cost of excellent and good, call the excellent to f2 f
> interviews/  visited their facilities,  if not known  etc. and start to
> refine the selection, calling the good ones etc till the amount available.
> If there were not enough good projects to reach the overall amount for the
> year , the difference  will be transferred to  FINEP ( www.finep.gov.br
> <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.finep.gov.br%2F&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881466330&sdata=KmUd%2BIJ1mh3hOrF3D1EZtzKuvJ3aYuiEHXrUEJeFqUg%3D&reserved=0>)
> a public Foundation,  kind of Bank,  to support R&D development and
> financing companies to improve their own R&D, as well as give grants to
> research centers or universities for smaller projects, still under the Law
> of Information Technology. Finep took about 30% of the amount to his own
> task.
>  The most difficult part was to control the development of the project –
> committee  members were assigned to follow up some projects  with
> staff/legal support, a quarter report is demanded from the grantee, till
> the deliverables were done.
> Both alternatives were used at the time: send money to third part  and
> just got the reports analyzed by the Committee,  and an “insideâ€
> management with the committee and third part staff/ legal contracted
> personnel.  My evaluation:
> Even less work sending money to the Foundation, the best results from
> projects  ( hence better $$ expended) we got from the work of the
> committee.
>
>
> Vanda Scartezini
> Polo Consultores Associados
> Av. Paulista 1159, cj 1004
> 01311-200- Sao Paulo, SP, Brazil
> Land Line: +55 11 3266.6253
> Mobile: + 55 11 98181.1464
> Sorry for any typos.
>
>
>
>
>
> From: Ccwg-auctionproceeds < ccwg-auctionproceeds-bounces at icann.org> on
> behalf of Alan Greenberg <alan.greenberg at mcgill.ca >
> Date: Friday, July 26, 2019 at 12:07
> To: Marilyn Cade <marilynscade at hotmail.com >, "
> ccwg-auctionproceeds at icann.org" < ccwg-auctionproceeds at icann.org>
> Cc: "Aikman-Scalese, Anne" <AAikman at lrrc.com>
> Subject: Re: [Ccwg-auctionproceeds] Judith Hellerstein's comments on the
> Auction Proceeds Draft
>
> Marilyn, although I have preferences, I will not here debate the options
> or even how we are to decide, but I would like more clarity on how you see
> the Mechanism C foundation operating.
>
> The only example we have for a corporation being set up in addition to
> ICANN is PTI. In that case, the majority of the PTI Board is appointed by
> ICANN (the rest being appointed by the ICANN NomCom), so it is had to claim
> that there is any independence. I presume that your intent would be to
> have, at the least, a majority of Foundation Board members being appointed
> NOT by ICANN. What level of majority for non-ICANN Board members do you
> consider reasonable and how would you see them being selected?
>
> You talk here about the potential for ICANN chargebacks being excessive.
> PTI purchases (ie outsources) a variety of services from ICANN (accounting,
> payroll, building space, etc.) Would you foresee the Foundation doing the
> same or are you suggesting that this not be allowed (ie the Foundation must
> be truly a stand-alone body providing all of its own services, or
> outsourcing them to some non-ICANN entity(ies).
>
> You talk about ICANN's salaries being excessive. How would you enforce
> lower salary levels in the Foundation when it would likely be co-located
> with ICANN and Foundation employees being able to be hired by ICANN for
> significant pay increases?
>
> The gist of my questions are that indeed, ICANN may have high operating
> costs, but I am unsure how the Foundation remedies it.
>
> A foundation *may* allow us to address such issues, but without clear
> ground rules, an "independent" foundation affiliated with ICANN could well
> have all of the same issues as those you associate with Mechanism A.
>
> Alan
>
>
> At 26/07/2019 10:30 AM, Marilyn Cade wrote:
>
> my apologies for being off line for a couple of days as other priorities
> did take over my life.
>
> As I represent the CSG, which is 3 constituencies, I will restate that we
> have strong concerns about Mechanism A as we do not understand how to
> ensure complete independence, which is of critical importance.  I can't say
> that have been able to fully consult recently with the other participants
> from the CSG, but the general direction has not changed.
>
> We supported Mechanism C, and our preference has not changed. Accepting
> that there needs to be two options, Mechanism A and Mechanism C presented
> to the community -- still we strongly require that there be more fact
> based, and not just opinions from each of us as participants, presented.
> Thus, while any of us may have experience or preference, the CSG prefers to
> see fact based and even external reports. We do not support relying on
> member or participant, or internal ICANN staff analysis on certain areas,
> as for Mechanism A, given the landfall of chargeback costs, there could be
> unrecognized preferences.
>
> Thus we want to see independent analysis of the key questions. and while
> we welcome ICANN legal and financial analysis, it is not sufficient.
> Further ICANN staff are not experts in grant making, grant management and
> while they can "count heads" and analyze certain functions such as
> completing the tax returns, the 990, etc., maintaining separate bank
> accounts, as they have done with the Auction Funds proceeds as an interim
> management function, this does not morph into a sophisticated grant
> management entity.
>
>
> Mechanism A: This in not the CSG preferred option.
> We have described our concern that there are issues about an in-house
> entity, with many issues related to how to be independent., lack of skills,
> hiring and firing of staff, increased liability to ICANN Org, overall, etc.
> etc
>
>  It is not accurate to state that because ICANN can set up separate bank
> accounts and maintain independence of such, that they are experienced in
> operating a truly independent grant making program. AND in operating such.
>
> An internal unit will have higher costs than are being acknowledged. On'e
> can't work part time on policy development or at GDD or GEE and then,
> presto, magic, morph over to spend 4 hours per day on a grant making
> program, at a lower costs, or at the same, higher cost of ICANN but without
> any clear distinction for tax reporting purposes.
>
> ICANN pays much higher salareies/benefits than is usual in a grant making
> entity and has also exit costs for staff who are part of ICANN and then are
> "made surplus", etc. And, not it isn't sufficient to cite California laws
> as if an employee is based in Europe, they gain additional benefits, like
> announcing they want to take a sabbatical to attend an educational program,
> and they simply are then still able to return to ICANN with a guarantee of
> job, as we have expeienced in the past. ICANN pays at far above usual rates
> for a not for profit organization, instead benchmarking against high tech
> companies -- this has been noted and objected to in the Budget Comments
> from the community, but is relevant here only as any "internal" process
> brings on exceptionally higher costs than is usual in a grant making/grant
> oversight/management process established in an external organization.
>
> I heard statements like: these staff can apply for ICANN jobs in the
> future, rather than being terminated. Let's be clear: grant making is a
> different skill set and we need to recognize that.
>
> In addition, the internal mechanism assumes that ICANN bills the "fund" at
> their usual really [well, I hesitate to use the word bloated, but certainly
> "high cost"] for any services they provide, and any services they provide
> are on top of what is supposed to be a full time job [according to the
> ICANN budget], which means retention of contractors, external resources, or
> additions of staff].  All at ICANN usual "costs".
>
> Again, higher than is usual for grant making organizations.
>
> The independence of any "internal body" is highly questionable.
>
> Stating that the ICANN Board has fiduciary responsibility, etc. is
> factual, but does not mean day to day oversight. And in fact, should be
> recognized as prohibited by the need for an independent disbursement
> mechanism.
>
> In fact, in the view of some, including the CSG and others in the public
> comment process, creating a mechanism with accountability, and independence
> from influence from Board and staff and even community, with focus on the
> established criteria led to members of the community to support Mechanism C
> over the recommendation of Mechanism A and B.
>
> Mechanism C remains our preferred option to present but we understand that
> it is possibly useful to present Mechanism A and C -- both -- as there is
> not agreement to a single mechanism at this point, among those who are
> active representatives and participants in this work effort. And it is
> important for us all to understand that this has been a prolonged and
> intensive effort.  And we are close to the end -- presenting, we hope --
> two options, with more detailed analysis and remaining questions, and then
> posting for our final public comment process.
>
> Frankly, as for me, there are continued questions about the influence of
> the staff and even the Board from time to time on this process  and whether
> it is appropriate to have "preferences" expressed, which occasionally I
> have feared that I tetected -- e.g. the Board prefers ... etc. or senior
> staff think... etc.
>
> I believe strongly, and advocated from when I became the CSG rep that it
> is essential to have a very stringent approach to fact based decision
> making, essential for a public service, not for profit corporation,
> incorporated under California law.  And an independent process that does
> not bring into ICANN a short term process, that is clearly not part of the
> core mission of ICXANN -- e.g grants management of a short term/but multi
> million$ fund, but one that is not part of why we created ICANN. Creating a
> separate Foundation, with a separate independent Board, with perhaps two ex
> officio non voting members that are from the ICANN Board, and a community
> advisory group
>
> I understand that some prefer to have the function inside ICANN. That is
> not supported by others in the members and participants, so a compromise is
> submitting Mechanism A and C, but then actually doing more due diligence as
> needed about each.
>
> Statements that a separate foundation is more expensive or longer than an
> internal mechanism are speculative right now, but can be addressed by
> factual analysis. However, I do not agree that ICANN staff have expertise
> in analyzing the attributes of staff or process to manage grant
> solutions/review/management. 🙂 Yes, they can set up separate bae bank
> accounts, and do other forms of administrative reporting, and of course,
> would have to be paid for at the usual ICANN [which is quite generous} fee
> basis. BUT, the background, experience, and skills to do grant
> solicitation,award/evalation is different.
>
> Recently an experienced colleague in grants management told me he managed
> a $80M grant which was dispersed in a 9 month announcement, award
> selection, then performance of 1 year period, with a second year
> management/evulation process, and described the overhead and reports.
> Another colleague told me about a $190M grant process -- again,
> dispursement/oversight/evaluation within a 3 year period.  These are not
> trivial tasks, and the overhead is what some might think is high, but is
> based on what kind of evaluation is required, and whether it is a grant to
> do something, or a grant to effect a major change. One might be light
> assessment- a) hold a meeting with 50 people/address training in DNSSEC, 40
> of those invited attended/ 35 received the credentials, etc. etc. versus:
> establish a multi year, multi country training program in capacity building
> in DNS issues and successfully bring in 200 attendees per year, with XX
> changes in skills at national level. Evaluate changes in expertise.
>
>
> Mechanism B had some attraction but there was not enough work on the
> criteria bout how to select the "partner" with experience/expertise in
> operating a grant making program.
>
> Thus, I hope that the CCWG-AP sending forward  Mechanism A and Mechanism C
> -- with the clear understanding that the CSG has many concerns with
> Mechanism A, and prefers Mechanism C.  And we will encourage informed
> comments during the public comment process.
>
> It is important to be clear about what the public comment process is about.
> I spent over an hour clarifying to Fellows and NextGen, who were
> encouraged by ICANN staff to express their "preference" on how to influence
> what is funded. This is a misunderstanding and probably on many parts. That
> is NOT the purpose of the CCWG-AP, and probably a misunderstanding by staff
> when they encouraged attending the CCWG-AP session but it is important to
> understand that this public comment includes a clear understandable
> statement that this is not a slush fund; it is not up to the ICANN Board to
> direct; it must be independently managed and not put ICANN's integrity, or
> tax status, or anti trust status at risk by any even suspicion.
>
> Boards change, so do Senior staff/executives. The community needs to have
> a good understanding of our responsibilities, but also our limitation,
> given the focused purpose of the Auction Proceeds.
>
> Marilyn Cade
> CSG member in the CCWG-AP
>
>
> From: Ccwg-auctionproceeds < ccwg-auctionproceeds-bounces at icann.org> on
> behalf of Judith Hellerstein <judith at jhellerstein.com >
> Sent: Thursday, July 25, 2019 11:25 PM
> To: Elliot Noss <enoss at tucows.com>
> Cc: ccwg-auctionproceeds at icann.org < ccwg-auctionproceeds at icann.org>
> Subject: Re: [Ccwg-auctionproceeds] Judith Hellerstein's comments on the
> Auction Proceeds Draft
>
> Hi Elliot
> Mechanism A is an internal icann department hired to do the evaluation and
> choosing of grants
> As such icann staff will be reviewing all grant applications and choosing
> the winners. This is why I said, to me it is clear, that this mechanism has
> the least independence and in my mind does not meet the requirements set up
> by the board.
>
> If icann outsourced the reviewing and selection of the grantees it us not
> clear to me what the difference of the mechanisms us to me.
>
> With mechanism b, this choice of reviewing and selecting the grant winners
> will be done by the donor advisory fund. This is and independent group
> where icann has no ability to influence
>
> Mechanism C is an icann foundation. Again an independent group reviews and
> select the grantees
>
> Hope this answers your questions
>
> Best
> Judith
>
> Sent from my iPhone
> Judith at jhellerstein.com
> Skype ID:Judithhellerstein
>
> On Jul 25, 2019, at 7:51 AM, Elliot Noss <enoss at tucows.com> wrote:
>
> Hi Judith,
>
> You say " It seems clear to me that Mechanism A would not meet the
> independent requirements set up by the ICANN Board†. This is not clear
> to me. Pleasse explain. Thanks.
>
> EN
>
> On Jul 24, 2019, at 11:02 PM, Judith Hellerstein <judith at jhellerstein.com
> > wrote:
>
> As per Emily's request, I am forwarding my comments to the entire list. I
> had previously sent them just to Staff and the Co-Chairs
>
> Best,
>
> Judith
>
> _________________________________________________________________________
>
>
>
> Judith Hellerstein, Founder & CEO
>
>
>
> Hellerstein & Associates
>
>
>
> 3001 Veazey Terrace NW, Washington DC 20008
>
>
>
> Phone: (202) 362-5139  Skype ID:
> judithhellerstein
>
>
>
> Mobile/Whats app: +1202-333-6517
>
>
>
> E-mail:
>
>
>
>
> Judith at jhellerstein.com
>
>
>
>    Website:
>
>
>
>
> www.jhellerstein.com <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.jhellerstein.com%2F&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881506356&sdata=oY%2FTXXfbQ5V1Vnsq9ZlAD%2FK6kKaKErpfTGhPJoaGpYE%3D&reserved=0>
>
>
>
> Linked In:
>
>
>
>
> www.linkedin.com/in/jhellerstein/ <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fjhellerstein%2F&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881536383&sdata=S%2Fep8Ov1zEgGmF0G7NPrZ2d4QgOEG6yr%2FwQzaYSyx%2Bg%3D&reserved=0>
>
>
>
> Opening Telecom & Technology Opportunities
> Worldwide
>
>
>
>
>
>
>
>
>
> -------- Forwarded Message --------
> Subject: Re: [Ext] My comments on the Auction Proceeds Draft
> Date: Wed, 24 Jul 2019 18:53:06 +0000
> From: Emily Barabas <emily.barabas at icann.org> <emily.barabas at icann.org>
> To: judith at jhellerstein.com <judith at jhellerstein.com>
> <judith at jhellerstein.com>, Marika Konings <marika.konings at icann.org>
> <marika.konings at icann.org>, erika at erikamann.com <erika at erikamann.com>
> <erika at erikamann.com>, Joke Braeken <joke.braeken at icann.org>
> <joke.braeken at icann.org> , ching.chiao at gmail.com <ching.chiao at gmail.com>
> <ching.chiao at gmail.com>
>
>
> Hi Judith,
>
> Would you mind sending your feedback to the CCWG mailing list, or if you
> would like staff can do so on your behalf? Just let us know which you
> prefer.
>
> Kind regards,
> Emily
>
>
> On 24/07/2019, 20:45, "Judith Hellerstein" <judith at jhellerstein.com>
> <judith at jhellerstein.com> wrote:
>
> HI Marika and Emily,
> I am attaching my comments on the auction proceeds draft document. It
> seems clear to me that Mechanism A would not meet the independent
> requirements set up by the ICANN Board but do not see this referenced in
> the report. Perhaps I am misunderstanding some things. I have also added
> comments about Mechanism B and C as well as other issues
>
> Earlier today, I have also  added comments to the google doc you posted
> today on the list serv
> Thanks for extending the deadline to Friday. Look forward to the call on
> Wednesday
>
> Best,
> Judith
> --
> _________________________________________________________________________
> Judith Hellerstein, Founder & CEO
> Hellerstein & Associates
> 3001 Veazey Terrace NW, Washington DC 20008
> Phone: (202) 362-5139 Skype ID: judithhellerstein
> Mobile/Whats app: +1202-333-6517
> E-mail: Judith at jhellerstein.com Website: www.jhellerstein.com
> <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.jhellerstein.com%2F&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881556411&sdata=demKXD0Y4aaAA1zvLgrZpeia%2FS%2FRcx4HEtEyKWniBOM%3D&reserved=0>
> Linked In: www.linkedin.com/in/jhellerstein/
> <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fjhellerstein%2F&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881576439&sdata=eiVtv%2BzcUCM2XxqpncBHl%2F8q%2FjdlRc%2FYASI5OKvfhW4%3D&reserved=0>
> Opening Telecom & Technology Opportunities Worldwide
>
> <new gTLD AP CCWG Draft Final Report - updated 28 June 2019-JH
> Rev.docx>_______________________________________________
> Ccwg-auctionproceeds mailing list
> Ccwg-auctionproceeds at icann.org
> https://mm.icann.org/mailman/listinfo/ccwg-auctionproceeds
> _______________________________________________
> By submitting your personal data, you consent to the processing of your
> personal data for purposes of subscribing to this mailing list accordance
> with the ICANN Privacy Policy ( https://www.icann.org/privacy/policy) and
> the website Terms of Service ( https://www.icann.org/privacy/tos
> <https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.icann.org%2Fprivacy%2Ftos&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881626470&sdata=gHfPcoJRI5C7CmA26NqHqqQ7QNYMlZVSlOq09HxQ6uQ%3D&reserved=0>).
> You can visit the Mailman link above to change your membership status or
> configuration, including unsubscribing, setting digest-style delivery or
> disabling delivery altogether (e.g., for a vacation), and so on.
>
> _______________________________________________
> Ccwg-auctionproceeds mailing list
> Ccwg-auctionproceeds at icann.org
> https://mm.icann.org/mailman/listinfo/ccwg-auctionproceeds
> _______________________________________________
> By submitting your personal data, you consent to the processing of your
> personal data for purposes of subscribing to this mailing list accordance
> with the ICANN Privacy Policy ( https://www.icann.org/privacy/policy) and
> the website Terms of Service ( https://www.icann.org/privacy/tos). You
> can visit the Mailman link above to change your membership status or
> configuration, including unsubscribing, setting digest-style delivery or
> disabling delivery altogether (e.g., for a vacation), and so on.
>
> _______________________________________________
> Ccwg-auctionproceeds mailing list
> Ccwg-auctionproceeds at icann.org
> https://mm.icann.org/mailman/listinfo/ccwg-auctionproceeds
> _______________________________________________
> By submitting your personal data, you consent to the processing of your
> personal data for purposes of subscribing to this mailing list accordance
> with the ICANN Privacy Policy ( https://www.icann.org/privacy/policy
> <https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.icann.org%2Fprivacy%2Fpolicy&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881696523&sdata=GrBHyDYG%2FJlUoHIvr53If5LfczCMM0a5yfK%2BdYyhaGs%3D&reserved=0>)
> and the website Terms of Service ( https://www.icann.org/privacy/tos
> <https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.icann.org%2Fprivacy%2Ftos&data=02%7C01%7C%7C3ad368d6e98e4c2e1e0008d7120014d7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636997663881706534&sdata=IQOWnA7UCbkGtmExlbGDIdSS1Im360Xie4e%2FYuV5zAY%3D&reserved=0>).
> You can visit the Mailman link above to change your membership status or
> configuration, including unsubscribing, setting digest-style delivery or
> disabling delivery altogether (e.g., for a vacation), and so on.
>
>
>
> ------------------------------
>
> This message and any attachments are intended only for the use of the
> individual or entity to which they are addressed. If the reader of this
> message or an attachment is not the intended recipient or the employee or
> agent responsible for delivering the message or attachment to the intended
> recipient you are hereby notified that any dissemination, distribution or
> copying of this message or any attachment is strictly prohibited. If you
> have received this communication in error, please notify us immediately by
> replying to the sender. The information transmitted in this message and any
> attachments may be privileged, is intended only for the personal and
> confidential use of the intended recipients, and is covered by the
> Electronic Communications Privacy Act, 18 U.S.C. §2510-2521.
>
> _______________________________________________
> Ccwg-auctionproceeds mailing list
> Ccwg-auctionproceeds at icann.org
> https://mm.icann.org/mailman/listinfo/ccwg-auctionproceeds
> _______________________________________________
> By submitting your personal data, you consent to the processing of your
> personal data for purposes of subscribing to this mailing list accordance
> with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and
> the website Terms of Service (https://www.icann.org/privacy/tos). You can
> visit the Mailman link above to change your membership status or
> configuration, including unsubscribing, setting digest-style delivery or
> disabling delivery altogether (e.g., for a vacation), and so on.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/ccwg-auctionproceeds/attachments/20190726/1a60e006/attachment-0001.html>