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.


  • English

Name: Zak Muscovitch
Date: 22 Oct 2021
Affiliation: Internet Commerce Association
Other Comments

Please refer to our attached PDF submission.

Summary of Attachment

The attached PDF files is the ICA's complete submission.

Summary of Submission

The Initial Report raises numerous issues which concern the Internet Commerce Association. Any proposed policy solution which “affects the right and ability of registrants to file judicial proceedings” and/or which fails to “preserve registrants’ rights to judicial review” of a UDRP or URS decision is unjust and will not comply with the clear and specific mandate given by ICANN’s GNSO Council to the EPDP. It is crucial that the GNSO Council carefully evaluate whether the policy proposals made in the Initial Report genuinely comply in substance and in spirit with the EPDP's specific mandate and ensure that registrant rights are protected.