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

[Manal Ismail]

+1 Kathy and Nigel on an “objection and comment period phase”, though I agree to deleting the word “credible”, per our last discussion, if it gives a negative connotation regarding comment periods in general ..

Kind Regards
--Manal

From: gnso-gac-closed-generics <gnso-gac-closed-generics-bounces at icann.org> On Behalf Of Nigel Hickson via gnso-gac-closed-generics
Sent: Wednesday, May 10, 2023 11:13 AM
To: Kathy Kleiman <Kathy at kathykleiman.com>
Cc: gnso-gac-closed-generics at icann.org
Subject: Re: [gnso-gac-closed-generics] Credible Comment Period

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<mailto: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
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