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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.

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Name: Ephraim Percy Kenyanito
Date: 19 Apr 2022
Affiliation: ARTICLE 19
Other Comments

Please find our comments attached as a PDF to this email.


At the beginning of March 2022, ICANN published the ICANN Uniform Domain Name Dispute Resolution Policy Status Report (UDRP Report), seeking input from the community.

We welcome the work of ICANN on releasing the document in line with Workstream 2 Recommendations on ICANN Transparency. Our analysis shows

that, primarily, the document contains several positive and commendable provisions, such as those related to proactive disclosure reporting.

However, we note that the UDRP Report fails to provide details of trademark and servicemark related cases or details of diversity data points which does not allow for sufficient independent human rights analysis and scrutiny of ICANN processes.

We also note that the UDRP Report uses the term “abuse” to generally address issues relevant to the UDRP, including trademark and service mark

infringements. Given its lack of clarity and specificity, ICANN should refrain from any use of the term “abuse” until there is a clear definition agreed by the ICANN community.

ARTICLE 19, therefore, urges ICANN to consider the recommendations below, which would help align the ICANN Status ICANN Uniform Domain Name Dispute Resolution Policy (UDRP Report) more closely with international law and best practices.

Summary of Attachment

Please find our comments attached as a PDF to this email.


At the beginning of March 2022, ICANN published the ICANN Uniform Domain Name Dispute Resolution Policy Status Report (UDRP Report), seeking input from the community.

We welcome the work of ICANN on releasing the document in line with Workstream 2 Recommendations on ICANN Transparency. Our analysis shows

that, primarily, the document contains several positive and commendable provisions, such as those related to proactive disclosure reporting.

However, we note that the UDRP Report fails to provide details of trademark and servicemark related cases or details of diversity data points which does not allow for sufficient independent human rights analysis and scrutiny of ICANN processes.

We also note that the UDRP Report uses the term “abuse” to generally address issues relevant to the UDRP, including trademark and service mark

infringements. Given its lack of clarity and specificity, ICANN should refrain from any use of the term “abuse” until there is a clear definition agreed by the ICANN community.

ARTICLE 19, therefore, urges ICANN to consider the recommendations below, which would help align the ICANN Status ICANN Uniform Domain Name Dispute Resolution Policy (UDRP Report) more closely with international law and best practices.

Summary of Submission

Please find our comments attached as a PDF to this email.


At the beginning of March 2022, ICANN published the ICANN Uniform Domain Name Dispute Resolution Policy Status Report (UDRP Report), seeking input from the community.

We welcome the work of ICANN on releasing the document in line with Workstream 2 Recommendations on ICANN Transparency. Our analysis shows

that, primarily, the document contains several positive and commendable provisions, such as those related to proactive disclosure reporting.

However, we note that the UDRP Report fails to provide details of trademark and servicemark related cases or details of diversity data points which does not allow for sufficient independent human rights analysis and scrutiny of ICANN processes.

We also note that the UDRP Report uses the term “abuse” to generally address issues relevant to the UDRP, including trademark and service mark

infringements. Given its lack of clarity and specificity, ICANN should refrain from any use of the term “abuse” until there is a clear definition agreed by the ICANN community.

ARTICLE 19, therefore, urges ICANN to consider the recommendations below, which would help align the ICANN Status ICANN Uniform Domain Name Dispute Resolution Policy (UDRP Report) more closely with international law and best practices.