Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Nat Cohen
Date: 24 Oct 2021
Affiliation: Telepathy, Inc.
Summary of Submission

Telepathy Inc. is opposed to the recommendations of the IGO EPDP, for the reasons provided in the attached comment.

While the IGOs serve a public purpose and understandably wish to have a means to address phishing, fraud and other abusive schemes, they can accomplish these goals without depriving registrants of the right of judicial review.

Numerous reputable organizations have made overreaching claims under the UDRP which required judicial review to correct. IGOs are likely to be no exception. Depriving registrants of judicial review attempts to rectify one harm by creating a new harm.

Several suggestions have been proposed for how the IGOs can successfully seek redress without depriving registrants of access to a judgment under the law. IGOs have wasted years of the community's time trying to use their political clout to try to push through an overreaching policy change that unnecessarily disadvantages respondents and that exceeds ICANN's mandate by interfering with registrants' access to the courts.