The gTLD Registries Stakeholder Group (RySG) welcomes the opportunity to comment on the draft ICANN Ombuds Office Framework and Process (the “Process”). We appreciate the Ombuds Office’s work to modernize its procedures for the benefit of the ICANN community, to ensure the ICANN community remains a space where all participants are welcomed and respected.

The definition for “Complainant” does not appear to be limited to members of the ICANN community, and in reviewing the Process it appears the intention of the Office of the Ombuds is to only accept cases that meet that definition. If this is correct, we propose the definition of “Complainant” be modified to reflect this limitation.

We further note that the Process should allow the possibility for a complaint to be received that relates to the Ombuds Office and/or Ombuds role in the event a Complainant wishes to raise a concern about its/their conduct and/or Process. The ICANN compliance function or Office of General Counsel would be an appropriate venue to receive such complaints in the event the case is about the Ombuds or Ombuds Office, and could implement this Process to remove the conflict that would be created with such a type of Complaint. 

The gTLD Registries Stakeholder Group (RySG) appreciates the Ombuds Office’s efforts to modernize its procedures and proposes clarifying the definition of “Complainant” as well as defining an appropriate venue for potential complaints related to the Ombuds Office or the Ombudsman.