Submitted By: George Kirikos Organization: Leap of Faith Financial Services Inc. Organization Website: http://www.leap.com/ Date: July 8, 2017 Thank you for the opportunity to comment on the Proposed Implementation of GNSO Consensus Policy Recommendations for the Protection of IGO&INGO Identifiers in All gTLDs, as documented at: https://www.icann.org/public-comments/igo-ingo-protection-2017-05-17-en 1. The text in section 4.2 of the draft document should be made clearer, to ensure that both transfers AND renewals are permitted. i.e. the use of "or" vs "and" might be too ambiguous the way it's currently worded. I propose that you change the text from: "....MUST permit renewal or transfer of the domain name." to: "...MUST permit renewals of the domain name and MUST permit transfers of the domain name." Notice how my proposed wording is unambiguous, and has only one possible interpretation, namely that BOTH are permitted. Repetition of the "MUST permit" helps immensely. [conceivably a registry might interpret the current language to permit one but not the other!] I've also made the terms "renewals" and "transfers" be in the plural form (current language is singular), to ensure that multiple renewals and multiple transfers must be allowed. 2. Draft section 4.4 is open to gaming: "4.4. Red Cross, IOC and IGO Identifier List Changes: Names may be added to or deleted from the Red Cross, IOC and IGO Identifier List upon ten (10) calendar days notice from ICANN to Registry Operator. ICANN will consult with the GAC in relation to proposed changes to the names on the Red Cross, IOC and IGO Identifier List." In particular, these organizations may in the future attempt to rename themselves into their shorter acronyms (eliminating any reference to their longer names), to gain protections that were explicitly NOT obtained via the GNSO Consensus policy. Furthermore, other organizations might be added that aren't "real" IGOs (the US government has disputed whether all entities that have made Article 6ter notifications are real IGOs, for example, in their comments to the IGO Curative Rights PDP; thus, it's open to debate whether there is a broad consensus about the status of future organizations that purport to be IGOs that seek to be on the list). Thus, Draft section 4.4 should be amended such that any additions to the list go through a more rigorous and public consultation, including a public comment period (in conjunction with the GNSO too), not just consultation with the GAC. That public comment period could then ensure that shorter domain names that have multiple competing uses (e.g. generic dictionary words, acronyms, etc.) are not added to the list. 3. In draft section 5.1, the list of organizations in the list at: https://community.icann.org/display/IIPIRT/INGO+Identifier+List+-+Draft+Page... includes generic terms such as "Rare" and "Mosaic" that can be used my many organizations or individuals. Furthermore, those INGOs may not have matching registered trademarks in many cases, which list the specific goods and/or services and geographic regions to which the trademarks would apply. Thus, I'm very concerned that any claims notice (in 5.2) will have a chilling effect, because the prospective registrant is not being provided sufficient details with which to make an informed decision as to whether their prospective use of the domain name would cause a real conflict with the INGO. Thus, either the claims notice should be scrapped in its entirely, or the list of organizations in the above link needs to be supplemented with additional columns to (a) identify the countries where those INGOs purport to operate and (b) identify what those INGOs actually do! (i.e. the goods/services that might cause a conflict). The text of Appendix A doesn't provide these details, either (it just provides various contact details for the INGO). Appendix A doesn't provide any details regarding how the INGOs use their purported protected names. In other words, there's a lot of work left to be done with respect to the claims notices and right now it's not even close to being ready for implementation, until those columns (and the relevant changes to Appendix A) are added. 4. Draft section 5.3 is open to the same kind of gaming I identified in my point #2 above. ICANN should consult with the GNSO *and* the public before adding additional names to the list, to ensure that shorter domain names that have multiple competing uses (e.g. generic dictionary words, acronyms, etc.) are not added to the list. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/