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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Potential amendments to UDRP
(1) The development of technologies and a vast interconnection of the world entails the rapid spreading of English as a universal language. That is why our suggestion is to supplement the Rules with the provision of English being the language of administrative proceedings as an alternative to the language of the Registration Agreement.
(2) In disputes related to "old" domains the statute of limitations issue often arises. Normally, when respondents invoke the doctrine of laches the panels state that mere delay between the registration of a domain name and the filing of the complaint neither bars a complainant from filing such a case, nor from potentially prevailing on the merits. Apparently, trademark owners cannot reasonably be expected to permanently monitor for every instance of potential trademark abuse, nor to instantaneously enforce each such instance they may become aware of. Therefore, our suggestion is to add to the Rules the statement on the inapplicability of the statute of limitations to the complaints to avoid a feasible ambiguity.