Please find attached Public Interest Registry's (PIR) submission to the public comment period on Proposed Updates to the GNSO Operating Procedures. PIR is providing this attachment in lieu of the Public Comment Proceeding Form.

Public Interest Registry (PIR) appreciates the opportunity to comment on the Proposed Updates to the GNSO Operating Procedures which includes recommendations from the GNSO Statement of Interest (SOI) Task Force. The strength of the multistakeholder model is built on the contributions of many, and varied, subject matter experts. These experts contribute their knowledge and experience to the ICANN Community to support the tenets of the multistakeholder model, including a firm commitment to transparency. However, a challenge often arises when participants in the multistakeholder process are unsure what positions or parties individuals are representing. PIR believes in a dedication to transparency as fundamental to the strength and continued effectiveness of the multistakeholder model.

PIR supports the updates to the GNSO Operating Procedures to include both the General SOI and Activity Specific SOI. However, due to an exception in the application of the proposal in the Sample Statement of Interest form, there is no real requirement that individuals disclose the identity or identities of who they represent in ICANN policymaking processes. This is an opportunity to further improve ICANN’s transparency to align with the trusted role it plays in Internet policymaking.  We encourage the GNSO to consider strong enforcement of the disclosure principle captured in the Activity Specific SOI.