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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Tucows welcomes the opportunity to comment on the second draft of the Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries (“RIR Governance Model”). The Regional Internet Registry (RIR) system is fundamental to the Internet and the DNS and while these recommended rules and criteria, in conjunction with the creation of guiding principles to outline the expectations of RIRs in the ecosystem, will improve the current state, there remains room for improvement regarding the involvement of stakeholders to ensure their voices are included in RIR governance.