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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.

Name: Registries Stakeholder Group (RySG)
Date: 23 Oct 2021
Affiliation: RySG
Other Comments

Overarching comments

The Registries Stakeholder Group (RySG) welcomes the opportunity to comment on the Initial Report from the EPDP on Specific Curative Rights Protections for IGOs.

We have some concern in general regarding changes to the URS and UDRP processes. However, we understand that IGOs have cited a unique set of jurisdictional challenges impacting their ability to avail themselves of various rights protection mechanisms (RPMs) and that this work was an attempt to accommodate their specific needs and will be utilized on a very limited basis. We would support the EPDP in reaching out to the GNSO to gather input from the RPM PDP, if possible, on these recommendations prior to finalizing them. We offer more specific input on some recommendations below.


Comments on the individual recommendations

●     Recommendation #1: Definition of “IGO Complainant”

The RySG believes this a clear and targeted definition that contributes to an appropriate scope for these recommendations. 

●     Recommendation #4: Arbitral Review following a UDRP Proceeding

The RySG supports Option 2. Where the avenue of judicial challenge to the UDRP decision is not available to the registrant as a result of the IGO’s refusal to submit to the jurisdiction of the Court, and the Court thereby declining to hear the action, then fairness would support the registrant being able to avail themselves of the proposed arbitration alternative.

●     Recommendation #5: Arbitral Review following a URS Proceeding

The RySG supports Option 2. See our comments to Rec #4.

Summary of Submission

The RySG has some concern in general regarding changes to the URS and UDRP processes. However, we understand that IGOs have cited a unique set of jurisdictional challenges impacting their ability to avail themselves of various rights protection mechanisms (RPMs) and that this work was an attempt to accommodate their specific needs and will be utilized on a very limited basis. We would support the EPDP in reaching out to the GNSO to gather input from the RPM PDP, if possible, on these recommendations prior to finalizing them. We offer more specific input on some recommendations below.