I raise the same concerns as the GNSO Council around their extensive contributions on the IGO-INGO Access to Curative Rights PDP and do agree that Recommendation #5 will most likely require a substantial modification to the UDRP and URS to make it more efficient. I agree with the IGOs concerning over the possibility of Recommendation 5# resulting in a serious reduction of the existing level of curative protections available to IGOs and I see the important and worthwhile need for the additional Policy work and this EPDP.

I would strongly recommend the Curative Rights PDP to develop a completely separate, narrowly-tailored dispute resolution procedure at the second level, which can be modeled on the UDRP and URS and one that takes into consideration the specific needs and special circumstances of IGOs and INGOs in their respective environments. This dispute resolution procedure cannot be developed effectively without the inclusive representation and active engagement of IGOs and INGOs throughout the process.

I support and completely believe in the EPDP’s strategy in modifying to the Rules applicable to the UDRP and URS, and the necessity to develop a definition clarifying the exact criteria for “IGO Complainants”. I completely agree that adding this definition will provide clearer eligibility requirements for IGOs in relation to the importance of demonstrating that they have adequate rights to proceed with a UDRP or URS complaint.

There must be a clear, transparent, and universally accepted guidelines within the community on the policy balance between an IGO’s privileges and immunities (especially in regards to their immunity from judicial processes).