All,
I’ve listed below some additional comments and suggestions on Section 1.12.
1.
1.12.1.e, first bullet: Need citation to statement that delegation deadline put into place to avoid squatting and warehousing
2.
1.12.1.f, 3rd sentence: Even if terms aren’t precisely defined, report should provide whatever definitions are being relied upon.
3.
1.12.1.f, para 2, 4th & 5th sentences: Confusing to have “use” in quotations. Juxtaposition of sentences 4 and 5 (not clear what use is, but use satisfied) is confusing.
4.
1.12.1.f, para 3, 3rd sentence: Need to explain what constitutes “actively used” – especially given statements in preceding paragraph.
5.
1.12.1.f, para 5, 2nd sentence: It’s a stretch to refer to targeted deadlines as SLAs (although I wish they had been).
6.
1.12.1.f, para 6, 3rd sentence: “in relation to this issue” is unclear. Identify the issue (e.g., in relation to X).
7.
1.12.1.f, para 6, 4th sentence: words missing after support – the view that?
8.
1.12.3.b, para 2: need citations to RA provisions
9.
1.12.3.c, 2nd sentence: replace “granular” with “detailed” and/or “more specific”
10.
1.12.3.e, question 1: need to provide basis for referring to application statements as “representations and/or commitments”; also, second-to-last question should be revised to ask commenter to explain why they’ve identified any specific
representations and/or commitments.
11.
1.12.3.e, question 2: Need to ask “How will the proposed mechanisms effectively address these issues”?
12.
1.12.3.f, para 1, 3rd sentence: Base Registry Agreement (for consistency)
13.
1.12.3.f, para 2: revise 4th bullet – Should representations made by the applicant be integrated into the Registry Agreement going forward and, if so, why and how?
14.
1.12.3.f, para 4, 2nd sentence: insert “, non-confidential” between “additional” and “data”
Talk to everyone later.
K
Kristina Rosette
Senior Corporate Counsel, IP – Domains