[gnso-gac-closed-generics] Credible Comment Period

[Kathy Kleiman]

Hi All,

Since we resume with the Comment Period discussion, I’d like to share 
the results of my research. Our GAC members inserted language that “*The 
evaluation process must include a credible objection and comment period 
phase”. *

To me this means a comment period /that is _part of the Evaluation 
Process_- /a comment period that a) lists all Closed Generic 
Applications, b) provides information about the criteria for their 
evaluation, AND c) gives companies, organizations, groups and 
associations time to think and respond.A special comment period for 
Closed Generic applications.

Comments are great!They are a cheap, easy, low-barrier way for the world 
to provide input to Closed Generic Applications. Plus, we agreed that 
_comments will be key to the Evaluators and their Evaluation process; 
silence may be misunderstood._

*In 2012, we had the first comment period after Reveal Day and then a 
second comment period in 2013 when the Board wanted to learn more about 
the concerns with the Closed Generic applications. [1].* It worked very 
well to separate these two comment periods. By 2013, articles had been 
written, Early Warnings were in, and groups and associations had shared 
articles with their members via newsletters and other publications.The 
second comment period allowed groups to come together with economic 
analysis and to sign comments about Closed Generic applications with 
multiple signatories representing a country or region – and that was 
very useful for assessing the concerns of business and industry groups.

*To have a credible comment period, I think we need a separate comment 
period.*

Some will argue that the comment period created by the SubPro WG – 
opening at/near Reveal Day (when all New gTLD applications are shared) 
is sufficient, but I don’t think so. This first round of comments is a 
very confusing time. There are thousands of applications, some with 
confusing language, and everyone is trying//to understand them and share 
initial comments.

It's enough time "to flag" broad concerns and let ICANN and others know 
there is a general problem, /but/ /not enough time for detailed analysis 
and organizing of groups and competitors that a Closed Generics 
Evaluation comment would enable./

A credible comment period that lists all Closed Generic Applications 
will give companies, ground, and organizations time to consider the 
Closed Generic – outside the “scramble period” of Reveal Day and in a 
way Evaluators of the new panels our Framework proposes can use.

Overall, comments are a cheap, easy way for groups, companies, 
competitors, associations and others to tell us what they think of 
Closed Generics.I think we should encourage them!

Best regards,

Kathy

Endnote:

[1] 
https://www.icann.org/en/public-comment/proceeding/closed-generic-gtld-applications-05-02-2013
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