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Request to Extend the 24-Day Comment Period on the Proposed VeriSign Agreement

Bruce Tonkin (MIT) wrote in the Registrars mailing list yesterday with this:


“We the undersigned registrars, request that the public comment period on the proposed agreement with Verisign be extended until Sunday 4 Dec 2005 so as to allow opportunities for in-person public discussions during the upcoming ICANN meeting in Vancouver. This we believe is consistent with the spirit of Article III, Section 6, paragraph 2 of the ICANN bylaws, which states that: “Where both practically feasible and consistent with the relevant policy development process, an in-person public forum shall also be held for discussion of any proposed policies as described in Section 6(1)(b) of
this Article, prior to any final Board action.”

In terms of process, the Registrar Constituency (RC) by-laws prevent the RC from balloting on anything in less than 24 days, and ICANN could require the interest groups it recognizes to have decision making processes that are capable of responding to the BOD’s [Board of Directors] decision making process, in a better administrative law world.

However, there are issues other than intra-ICANN recognized interest group process, at least in my mind.

The “in-person public forum” simply means having the Vancouver ICANN meeting occur during the comments period. What difference this could make escapes me. First, having gone to Rome to oppose VGRS’s Site Finder, along with most other Registrars (NSI opposed, RCOM and Bulk abstained on a RC ballot motion intended to inform the BOD on the issue), the effect of the in-person corporate fora was invisible. The efficacy or significance of an “in-person public forum” on VGRS’s primary lobbying interest area is not self-evident.

Supposing it was, the registrars which engage in competitive lobbying at the “in-person public fora” are generally the larger, and the more innovative, where “innovative” means organized around some value propositions that necessitates lobbying, proactive, or unfortunately, reactive. Advocacy of this subset of persons and represented interests within the competing actors and interest groups that lobby is just that, it isn’t discussion of proposed policies.

A discussion period of 90 days is, in my opinion, unrushed and allows for the mature development of issues. I’ll be writing to the BOD, just as Bruce will.

Eric Brunner-Williams
ICANN Registrar #439, CORE #124
Walillak daligen (The Truth is out there…)

By Eric Brunner-Williams, Mathematician

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