Hi Christopher, thanks for this comment which is much appreciated. Would you like or suggest your comment being submitted as a EURALO POV or statement during the public comment period. Or would you and Jean-Jacques serve as pen holders for another or more detailed one? Thanks for your advice and kind regards, Wolf Christopher Wilkinson wrote Sat, 22 Mar 2014 19:48:

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Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries.

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Good evening:

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I do not support this proposal. If these new gTLD are subject to such risks of egregious malpractice that even the industries that they are supposed to serve do not support them, let alone their regulatory agencies and governments, then these 'strings' should not be delegated at all.

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The proposed Policy Advisory Boards are clearly a palliative for a wider issue that has not yet been addressed:

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1. By constituting such ICANN-esque global regulatory agencies in each of the sectors concerned, ICANN would expose itself to unprecedented obligations and liabilities which it is in no position to discharge, world-wide.

2. There is no reference to the real costs of the Policy Advisory Boards, their autonomy, authority and their recourse in the event of disputes.

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To be meaningful in any sense, these PABs would require full-time professional positions. The original proposal refers to the PABs being financed exclusively by the Registry concerned, which is manifestly absurd.

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They would have to be financed directly by ICANN, to ensure a minimum of independence.

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3. The original proposal envisages a small PAB (12-18 members) for each Registry, representing eleven or more categories of interest groups, world-wide, not including governments. The internal inconsistency of the proposal is self-evident.

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4. The proposed text sets the bar for compliance excessively low. Here we have the PAB ensuring that the Registry does not operate in a manner that is “... antithetical to the overriding goals of competition and innovation.” Nothing more?

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Consequently, it would appear to be inconsistent with the public interest to pursue “the further development of the PAB model” until the eventual Registries themselves propose credible and viable global solutions to the issues that have been identified.

Regards

Christopher Wilkinson

PS: The At Large mail server succeeded in deleting all the formatting from my original message, rendering it almost illegible. So I am resending the original text. Apologies for double posting. CW

On 22 Mar 2014, at 02:59, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:

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[http://www.icann.org/images/gradlogo_bow.jpg]<http://www.icann.org/> News Alert

http://www.icann.org/en/news/announcements/announcement-21mar14-en.htm

________________________________ Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings

21 March 2014

Forum Announcement: Comment Period Opens on Date: 21 March 2014 Categories/Tags:

* Top-Level Domains * Contracted Party Agreements

Purpose (Brief): The purpose of this public comment period is to obtain feedback and collect broader community input into the further development of the PAB model, and to which TLD strings it may best apply. Public Comment Box Link: http://www.icann.org/en/news/public-comment/pab-new-gtld-strings-21mar14-en....

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