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.
The attachment is in addition to the summary public comment.
The UDRP process was designed for black & white cases of trademark abuse. Most disputes seem to fall under this group.
As is, it works well for these types of clear-cut cases.
The problem occurs when you start dealing with more generic types of domains; domains with many potential uses that often have high value on the open market.
The value of these domains has risen dramatically since the UDRP policy was first created and the policy needs to be balanced to recognize both trademark holders AND registrant rights.