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: Zoe Bonython
Date: 24 Oct 2021
Affiliation: Registrar Stakeholder Group (RrSG)
Summary of Submission

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 recommendations 3 & 4, with regards to the exemption of IGOs from submitting to a mutual jurisdiction for appeals of UDRP and URS proceedings, and recommendations 4 & 5, with regards to the arbitration process being used to appeal a URS or UDRP Decision or Determination.