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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Submissions for this Proceeding
Initial Report from the EPDP on Specific Curative Rights Protections for IGOs
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Protection of Domain Name Registrant Rights
We are confused why all of this work and effort has been put into this new proposed policy considering IGO-INGO’s already have access to the UDRP system. We don’t understand the problem this working group is attempting to solve.
We also do not support removing mutual jurisdiction or support ICANN offering immunity if the IGO-INGO has elected to initiate a UDRP or URS proceeding. We do not support forcing arbitration – as ...
Namecheap thanks the EPDP for its work, however is concerned that the Interim Report is not representative of ICANN's multistakeholder model. The report does not consider the interests of other ICANN constituencies, is biased in favor of trademark owners and arbitration providers, and ignores domain name registrants completely. Additionally, the recommendations seek to create new trademark rights for IGOs, anticipates costly arbitration that r...
Please find attached (PDF) the ALAC Statement on the Initial Report from the EPDP on Specific Curative Rights Protections for IGOs.
Ratification information is included on the cover page.
ICANN Policy Staff in support of the At-Large Community
The World Bank has participated as an Observer to the Work Track that prepared the proposal now under public comment. We support the comments of the GAC submitted on 22 October 2021, as well as the comments of WIPO submitted on 22 October 2021.
The Registrar Stakeholder Group (RrSG) appreciates the significant effort of the EPDP in reviewing this issue, but has serious concerns about a number of the recommendations in the Interim Report that are contrary to the EPDP’s charter, the position of the ICANN Board, and could prejudice the rights of domain name registrants.
The RrSG's concerns are outlined in full in the attached comment.
Of particular concern for the RrSG are...
Whatever path that the GNSO decides to take in connection with IGO participation in RPMs, it is critical that it be examined from a holistic perspective in the near and mid-term as part of the RPM Review PDP to ensure that the approach remains internally consistent and effective.
The Organisation for Economic Co-operation and Development (OECD) fully endorses the comments made by the GAC and WIPO.
We would reiterate that international organisations (IOs) are not seeking to deprive registrants of legitimately held domain names but merely seeking protections from abuse by cybersquatters which are consistent with their unique status under international law. As WIPO demonstrates, IOs are vulnerable to cybersquatting ...
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 requir...
I am resolutely opposed to the proposed recommendations, which would inequitably skew the landscape for dispute resolution in favour of IGOs.
I fully support the submissions made by both George Kirikos and the Internet Commerce Association:
We support the position of George Kirikos of Leap of Faith Financial Services Inc., submitted Oct 23rd.
Before going further in this project, and in order to ICANN transparency policies, please provide this report in the six United Nations languages. This will let more people understand and participate in this very important case.
OPPOSED to proposed changes on Specific Curative Rights Protections for International Governmental Organizations
There are smaller owners, like myself that would not be served well if you made UDRP worse for us.
Am I right in my understanding that this proposed policy change would result in legitimate domain owners losing their domain names because anyone would be able to pay a fee to have a random person make a purely personal decision on the fate of the domain without being held accountable for their actions, even if they are in violation of any rightful logic? Oh wait, that is already the case in so many ridiculous unjust UDRP proceedings. Now ...
We are opposed to the entire report. It is a product of capture, as documented by a detailed analysis of the participation levels of the new working group.
Instead, we propose an alternative "Notice of Objection" system which would be a win-win for both IGOs and for domain name registrants, as it has the ability to eliminate the mutual jurisdiction clause while still preserving the full legal rights of domain name registrants.
(please see attachment)
In strong agreement with the Internet Commerce Association and George Kirikos.
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...
Domain registrants' rights to judicial review must be preserved.