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: Sarah Wyld
Date: 17 Oct 2025
Affiliation: Tucows
Summary of Attachment


Summary of Submission

Tucows appreciates the opportunity to comment and thanks ICANN Org for drafting.

In order to successfully address concrete issues by creating Policy that will solve real problems, the Charter must be split up into three Charters for three separate, sequential “micro”-PDPs.

The representative model works only when it is truly representative; as such the Charter should be updated to ensure even numbers across Stakeholder Groups.

The Charter should be updated to include a requirement that the WG perform a Data Protection Impact Assessment in addition to the planned Human Rights Impact Assessment. Further, PDPs that have effects on registrants (all PDPs) should include consideration of recourse and dispute mechanisms available to registrants.

Finally, Tucows supports the RrSG's Public Comment and the CPH DNS Abuse WG's Public Comment on this Report.