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

[Nigel Hickson]

Good morning

Thanks to Kathy for this lucid and constructive note; indeed think a
separate and well flagged comment period for this special class of
application is entirely appropriate;

Best

Nigel

On Wed, 10 May 2023, 02:58 Kathy Kleiman, <Kathy at kathykleiman.com> wrote:

> 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
> _______________________________________________
> gnso-gac-closed-generics mailing list
> gnso-gac-closed-generics at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-gac-closed-generics
>
> _______________________________________________
> 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: <https://mm.icann.org/pipermail/gnso-gac-closed-generics/attachments/20230510/10005564/attachment.html>