<div dir="auto">Good morning <div dir="auto"><br></div><div dir="auto">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;</div><div dir="auto"><br></div><div dir="auto">Best</div><div dir="auto"><br></div><div dir="auto">Nigel </div></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Wed, 10 May 2023, 02:58 Kathy Kleiman, <<a href="mailto:Kathy@kathykleiman.com">Kathy@kathykleiman.com</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">
<div>
<p class="MsoNormal">Hi All,</p>
<p class="MsoNormal"><span style="font-size:12.0pt;line-height:107%;font-family:"Times New Roman",serif">Since we resume with the
Comment Period discussion, I’d
like to share the results of my research. Our GAC members
inserted language
that </span>“<b><span style="font-family:"Arial",sans-serif;color:black">The
evaluation process must include </span><span style="background:yellow"><span style="white-space:pre-wrap">a credible objection and comment period phase</span>”.
</span></b><span style="font-size:12.0pt;line-height:107%;font-family:"Times New Roman",serif"></span></p>
<p>To me this means a comment period <i>that is <u>part of the Evaluation Process</u>- </i>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.<span>
</span>A special comment period for Closed Generic applications.</p>
<p>Comments are great!<span>
</span>They are a cheap, easy, low-barrier way for the world to
provide input
to Closed Generic Applications. Plus, we agreed that <u>comments
will be key to
the Evaluators and their Evaluation process; silence may be
misunderstood.</u> </p>
<p><b>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].</b> 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.<span> </span>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. </p>
<p><b>To
have a credible
comment period, I think we need a separate comment period.</b></p>
<p>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<i> </i>to
understand
them and share initial comments. </p>
<p>It's enough time "to flag" broad concerns and
let ICANN and others know there is a general problem, <i>but</i> <i>not
enough time for
detailed analysis and organizing of groups and competitors that
a Closed
Generics Evaluation comment would enable.</i> </p>
<p>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.<span> </span></p>
<p>Overall, comments are a cheap, easy way for
groups,
companies, competitors, associations and others to tell us what
they think of
Closed Generics.<span> </span>I think
we should
encourage them! </p>
<p>Best regards, </p>
<p>Kathy</p>
<p>Endnote: </p>
<p>[1] <a href="https://www.icann.org/en/public-comment/proceeding/closed-generic-gtld-applications-05-02-2013" target="_blank" rel="noreferrer">https://www.icann.org/en/public-comment/proceeding/closed-generic-gtld-applications-05-02-2013</a></p>
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