Re: [Gnso-newgtld-wg] New gTLD Subsequent Procedures PDP WG - Initial Report
As everyone knows, I also support the approach of finalizing the version for public comment AFTER the meeting in Panama, as did many commenters on the last call. It’s a policy meeting. The Preamble looks good with the exception of the following: A. “different” should be “differently” B. “man-hours” should be “hours” Listing the questions for public comment in separate Annexes (with links to the deliberations) is a terrific idea. Thank you Leadership for thinking of this! I think Jeff made it clear on the last call that members of the Working Group could submit changes and comments up until Friday June 29. That makes sense. Due to time constraints on the drafting process, I am underlining the items below (from my previous comments) in advance of seeing the revisions. These revisions are necessary to accurately reflect discussions in Work Tracks 3 and 4 respectively. With respect to work actually discussed in the Work Tracks, I was disappointed that several issues I raised in those (time-consuming) discussions did not appear in the draft Initial Report. I have raised these again (and again – even going back and documenting them from the calls in the case of Work Track 4) and will be looking for revisions to the draft report to accurately reflect those discussions. Some of the more significant are: 1. Predictability Framework. The proposed framework is duplicative of the GNSO Procedures already adopted by the Board for GNSO Input, GNSO Guidance, and Expedited PDP. At first Jeff and Steve Chan thought these existing procedures only applied to the pre-launch phase. This is obviously not the case and was never intended by the P & I Working Group. Many of the examples provided in the draft Initial Report were carefully studied by the WG before recommending the policy to the GNSO which was later adopted by the Board and now appears in the GNSO Operating Procedures Annexes. This was mentioned several times in the plenary calls. The conflict should be highlighted, as should be clear from the fact that the GNSO is now launching an EPDP. 2. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment. 3. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem. 4. Definition of “community”. I raised the Principle of Freedom of Expression numerous times within Work Track 3 discussions in relation to concerns that the proposed policy change to narrow the definition of community to those community applications that are “deserving” of CPE violates that principle and involves content regulation that is beyond ICANN’s Mission. This issue did not appear in the initial draft report so I had to raise it again in the full WG calls. Karen Day says that she and Robin Gross are “on it” so thank you Karen! It is not appropriate for any of the above issues to be “sidelined” by suggesting that the WG post the comments to the public comment section rather than describing the issues in the Initial Report exactly as they were raised in the Work Track discussions. I agree with those who have remarked that if the issues clearly raised in the Work Tracks are not clearly set forth for public comment, the failure will merely “blow up later”. In this regard, I have never had this much trouble getting bottom-up participation reflected, notwithstanding the fact that Jeff is doing a yeoman’s job in dealing with this much material and trying to coordinate his Work Track leaders. Thank you Jeff. Anne Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ [cid:image003.png@01D407C1.74F1C030] Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com/> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Jonathan Robinson Sent: Tuesday, June 19, 2018 9:02 AM To: 'Jon Nevett'; 'Jeff Neuman' Cc: gnso-newgtld-wg@icann.org Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC I’d like to support Jon here. This seems like a sensible approach. Jonathan From: Jon Nevett [mailto:jon@donuts.email] Sent: Tuesday, June 19, 2018 4:11 PM To: Jeff Neuman <jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com>> Cc: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC Jeff: There are a number of examples, like this one, where I am hearing about last minute proposed improvements to the report. We should have the time in Panama to go through theses changes vs. on the fly now. I propose that we consider and make any final clarifications/improvements in Panama. We should lock down the report after Panama and then send it out for public comment. Locking it down before Panama would only prevent us from making final clarifications and improvements necessitating comments on stale or incorrect language. Wouldn't we be better off getting comments on a better version? Thx. Jon On Jun 19, 2018, at 7:40 AM, Jeff Neuman <jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com>> wrote: All, I think we can find a way to incorporate Kristina and Anne's comments because upon thinking about this, they are correct. Although the Guidebook uses the term "infringe" many times, technically, the Guidebook does not use an "infringement" standard in the supporting text. Perhaps generalizing the text to just ask if the standard that was applied was the correct one. So how about this: • Should the standard for the Legal Rights Objection remain the same as in the 2012 round? Please explain. And we drop a footnote quoting section 3.5.2 in full as Anne did below. Does that work? Jeffrey J. Neuman Senior Vice President |Valideus USA | Com Laude USA 1751 Pinnacle Drive, Suite 600 Mclean, VA 22102, United States E: jeff.neuman@valideus.com<mailto:jeff.neuman@valideus.com> or jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com> T: +1.703.635.7514 M: +1.202.549.5079 @Jintlaw -----Original Message----- From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces@icann.org<mailto:gnso-newgtld-wg-bounces@icann.org>> On Behalf Of Rubens Kuhl Sent: Monday, June 18, 2018 10:26 PM To: Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> Cc: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC Anne, The policy reads "Strings must not infringe the existing legal rights of others that are recognized or enforceable under generally accepted and internationally recognized principles of law." (Source: https://gnso.icann.org/en/issues/new-gtlds/pdp-dec05-fr-parta-08aug07.htm) Anything different than that, including AGB which was supposed to be its implementation when it does not follow policy, is a change of GNSO policy. It also doesn't work picking 1 AGB reference when other 3 references in AGB say exactly what the GNSO policy says. We can't just pick references that go to one view and not the others from the same document. Rubens
On 18 Jun 2018, at 23:00, Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> wrote:
Rubens, This is definitely not a “change in policy” that Kristina and I are suggesting. The clear language of the AGB which codifies the grounds for the LRO is at 3.5.2 as follows:
3.5.2 Legal Rights Objection In interpreting and giving meaning to GNSO Recommendation 3 (“Strings must not infringe the existing legal rights of others that are recognized or enforceable under generally accepted and internationally recognized principles of law”), a DRSP panel of experts presiding over a legal rights objection will determine whether the potential use of the applied-for gTLD by the applicant takes unfair advantage of the distinctive character or the reputation of the objector’s registered or unregistered trademark or service mark (“mark”) or IGO name or acronym (as identified in the treaty establishing the organization), or unjustifiably impairs the distinctive character or the reputation of the objector’s mark or IGO name or acronym, or otherwise creates an impermissible likelihood of confusion between the applied-for gTLD and the objector’s mark or IGO name or acronym.
Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ <image003.png> Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com>
From: Rubens Kuhl [mailto:rubensk@nic.br] Sent: Monday, June 18, 2018 6:06 PM To: Aikman-Scalese, Anne Cc: Rosette, Kristina; gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
Anne and Kristina,
While we can reckon the actual standard used in 2012, we can't simply ignore that we have - The current applicable GNSO Recommendation (3) saying infringement - Three AGB references using infringement 3.2.1 Grounds for Objection Legal Rights Objection – The applied-for gTLD string infringes the existing legal rights of the objector. 3.2.2.2 Legal Rights Objection A rightsholder has standing to file a legal rights objection. The source and documentation of the existing legal rights the objector is claiming (which may include either registered or unregistered trademarks) are infringed by the applied-for gTLD must be included in the filing. Attachment to Module 3 Article 2 (e) (ii) “Existing Legal Rights Objection” refers to the objection that the string comprising the potential new gTLD infringes the existing legal rights of others
(not counting 3.5.2, where infringement is redefined to the criteria actually used)
That means that in order to keep 2012 status-quo, the policy recommendation needs to be changed and AGB also needs to be changed.
What I find curious is that ICANN's own Program Implementation Review failed to acknowledge this deviation from policy, and we probably need to state that somehow. Even if the PDP finds that it was for the better, and it looks that way to me, we shouldn't miss the learning that this mistake provided.
Rubens
On 18 Jun 2018, at 19:07, Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> wrote:
I support Kristina’s comments shown in the attachment and note that she also states in her comment on page 10 that the LRO in 2012 was not an “infringement” standard. Kristina suggests in the attachment that we simply refer to the “standard used in 2012” if we are not willing to set out the three grounds set forth in the AGB and copied again below.
This same reference to “infringement analysis” occurs on page 15 of draft Section 1.8 so the language there should be conformed to the language chosen for page 10.
Again, the standard for LRO from 2012 is as follows:
As provided for in section 3.5.2 of the ICANN Applicant Guidebook, the independent panel will determine whether the potential use of the applied-for gTLD by the applicant: (i) takes unfair advantage of the distinctive character or the reputation of the objector’s registered or unregistered trademark or service mark (“mark”) or IGO name or acronym, or (ii) unjustifiably impairs the distinctive character or the reputation of the objector’s mark or IGO name or acronym, or (iii) otherwise creates an impermissible likelihood of confusion between the applied-for gTLD and the objector’s mark or IGO name or acronym.
Anne
Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ <image003.png> Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com>
From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Rosette, Kristina via Gnso-newgtld-wg Sent: Monday, June 18, 2018 7:52 AM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
This time with attachment. Apologies.
From: Rosette, Kristina Sent: Monday, June 18, 2018 10:51 AM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Cc: 'Steve Chan' <steve.chan@icann.org<mailto:steve.chan@icann.org>> Subject: RE: [Gnso-newgtld-wg] Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
My comments and suggestions on 1.8 attached.
From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Steve Chan Sent: Sunday, June 17, 2018 1:25 PM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: [Gnso-newgtld-wg] Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
Dear WG Members,
With apologies for the late delivery, please find the proposed agenda for the New gTLD Subsequent Procedures WG meeting scheduled for 18 June 2018 at 15:00 UTC, for 90 minutes.
• Agenda Review • Roll Call/SOIs • Review of the Initial Report (continued). * The purpose of this review is to ensure that preliminary outcomes and deliberations are accurately captured and written in an understandable manner. The WG Co-Chairs have sought to make clear that this exercise is not intended to re-open substantive discussions, which is better served by the submission of public comments and subsequently when reviewing public comments received. Please submit your comments about these sections to the Working Group mailing list (gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org>) in advance of the meeting. • Review of Section 1.8 (Accountability Mechanisms) • Review of Section 1.9 (Community Applications) • Review of other sections in the Initial Report • AOB
For Item 3, the relevant documents are attached. As a reminder, please note that a resource page has been set up on the Wiki to track the distribution of Initial Report sections, which you can find here: https://community.icann.org/x/NwUhB.
For Item 4, you will find a draft of most of the other sections within the Initial Report, including the Preamble and the Executive Summary. You will see a placeholder in Section 2, which states, “Insert sections from the excerpts reviewed by Working Group…” – here, staff will insert the sections we have been reviewing for the last couple of months, inclusive of any changes as needed from discussions on calls and on list.
Those signed up as Members to this PDP WG should have received meeting information from the SOAC Support team. If you did not receive these participation details or if you would like to send your apologies, please contact the SOAC Support team (gnso-secs@icann.org<mailto:gnso-secs@icann.org>).
Best, Steve
Steven Chan Policy Director, GNSO Support
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Thanks Anne and everyone. Anne – When you see the redlines today, I think you will find that all of your comments are included. Everyone else -We understand the views of the group. As previously stated, there is a leadership call in about 8 hours from now. The leadership team includes all of the work track leads and of course we will discuss your views. I do not want to make a unilateral call on this topic because of its importance to the entire leadership team and make sure that the track we choose to go down has full support from the team. So lack of a response for the next 8 hours does not mean we are ignoring you. Thanks. Jeffrey J. Neuman Senior Vice President |Valideus USA | Com Laude USA 1751 Pinnacle Drive, Suite 600 Mclean, VA 22102, United States E: jeff.neuman@valideus.com<mailto:jeff.neuman@valideus.com> or jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com> T: +1.703.635.7514 M: +1.202.549.5079 @Jintlaw From: Aikman-Scalese, Anne <AAikman@lrrc.com> Sent: Tuesday, June 19, 2018 2:34 PM To: 'jrobinson@afilias.info' <jrobinson@afilias.info>; 'Jon Nevett' <jon@donuts.email>; Jeff Neuman <jeff.neuman@comlaude.com> Cc: gnso-newgtld-wg@icann.org Subject: RE: New gTLD Subsequent Procedures PDP WG - Initial Report As everyone knows, I also support the approach of finalizing the version for public comment AFTER the meeting in Panama, as did many commenters on the last call. It’s a policy meeting. The Preamble looks good with the exception of the following: 1. “different” should be “differently” 2. “man-hours” should be “hours” Listing the questions for public comment in separate Annexes (with links to the deliberations) is a terrific idea. Thank you Leadership for thinking of this! I think Jeff made it clear on the last call that members of the Working Group could submit changes and comments up until Friday June 29. That makes sense. Due to time constraints on the drafting process, I am underlining the items below (from my previous comments) in advance of seeing the revisions. These revisions are necessary to accurately reflect discussions in Work Tracks 3 and 4 respectively. With respect to work actually discussed in the Work Tracks, I was disappointed that several issues I raised in those (time-consuming) discussions did not appear in the draft Initial Report. I have raised these again (and again – even going back and documenting them from the calls in the case of Work Track 4) and will be looking for revisions to the draft report to accurately reflect those discussions. Some of the more significant are: 1. Predictability Framework. The proposed framework is duplicative of the GNSO Procedures already adopted by the Board for GNSO Input, GNSO Guidance, and Expedited PDP. At first Jeff and Steve Chan thought these existing procedures only applied to the pre-launch phase. This is obviously not the case and was never intended by the P & I Working Group. Many of the examples provided in the draft Initial Report were carefully studied by the WG before recommending the policy to the GNSO which was later adopted by the Board and now appears in the GNSO Operating Procedures Annexes. This was mentioned several times in the plenary calls. The conflict should be highlighted, as should be clear from the fact that the GNSO is now launching an EPDP. 1. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment. 1. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem. 1. Definition of “community”. I raised the Principle of Freedom of Expression numerous times within Work Track 3 discussions in relation to concerns that the proposed policy change to narrow the definition of community to those community applications that are “deserving” of CPE violates that principle and involves content regulation that is beyond ICANN’s Mission. This issue did not appear in the initial draft report so I had to raise it again in the full WG calls. Karen Day says that she and Robin Gross are “on it” so thank you Karen! It is not appropriate for any of the above issues to be “sidelined” by suggesting that the WG post the comments to the public comment section rather than describing the issues in the Initial Report exactly as they were raised in the Work Track discussions. I agree with those who have remarked that if the issues clearly raised in the Work Tracks are not clearly set forth for public comment, the failure will merely “blow up later”. In this regard, I have never had this much trouble getting bottom-up participation reflected, notwithstanding the fact that Jeff is doing a yeoman’s job in dealing with this much material and trying to coordinate his Work Track leaders. Thank you Jeff. Anne Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ [cid:image001.png@01D407DB.8BFB9520] Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com/> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Jonathan Robinson Sent: Tuesday, June 19, 2018 9:02 AM To: 'Jon Nevett'; 'Jeff Neuman' Cc: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC I’d like to support Jon here. This seems like a sensible approach. Jonathan From: Jon Nevett [mailto:jon@donuts.email] Sent: Tuesday, June 19, 2018 4:11 PM To: Jeff Neuman <jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com>> Cc: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC Jeff: There are a number of examples, like this one, where I am hearing about last minute proposed improvements to the report. We should have the time in Panama to go through theses changes vs. on the fly now. I propose that we consider and make any final clarifications/improvements in Panama. We should lock down the report after Panama and then send it out for public comment. Locking it down before Panama would only prevent us from making final clarifications and improvements necessitating comments on stale or incorrect language. Wouldn't we be better off getting comments on a better version? Thx. Jon On Jun 19, 2018, at 7:40 AM, Jeff Neuman <jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com>> wrote: All, I think we can find a way to incorporate Kristina and Anne's comments because upon thinking about this, they are correct. Although the Guidebook uses the term "infringe" many times, technically, the Guidebook does not use an "infringement" standard in the supporting text. Perhaps generalizing the text to just ask if the standard that was applied was the correct one. So how about this: • Should the standard for the Legal Rights Objection remain the same as in the 2012 round? Please explain. And we drop a footnote quoting section 3.5.2 in full as Anne did below. Does that work? Jeffrey J. Neuman Senior Vice President |Valideus USA | Com Laude USA 1751 Pinnacle Drive, Suite 600 Mclean, VA 22102, United States E: jeff.neuman@valideus.com<mailto:jeff.neuman@valideus.com> or jeff.neuman@comlaude.com<mailto:jeff.neuman@comlaude.com> T: +1.703.635.7514 M: +1.202.549.5079 @Jintlaw -----Original Message----- From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces@icann.org<mailto:gnso-newgtld-wg-bounces@icann.org>> On Behalf Of Rubens Kuhl Sent: Monday, June 18, 2018 10:26 PM To: Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> Cc: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC Anne, The policy reads "Strings must not infringe the existing legal rights of others that are recognized or enforceable under generally accepted and internationally recognized principles of law." (Source: https://gnso.icann.org/en/issues/new-gtlds/pdp-dec05-fr-parta-08aug07.htm) Anything different than that, including AGB which was supposed to be its implementation when it does not follow policy, is a change of GNSO policy. It also doesn't work picking 1 AGB reference when other 3 references in AGB say exactly what the GNSO policy says. We can't just pick references that go to one view and not the others from the same document. Rubens
On 18 Jun 2018, at 23:00, Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> wrote:
Rubens, This is definitely not a “change in policy” that Kristina and I are suggesting. The clear language of the AGB which codifies the grounds for the LRO is at 3.5.2 as follows:
3.5.2 Legal Rights Objection In interpreting and giving meaning to GNSO Recommendation 3 (“Strings must not infringe the existing legal rights of others that are recognized or enforceable under generally accepted and internationally recognized principles of law”), a DRSP panel of experts presiding over a legal rights objection will determine whether the potential use of the applied-for gTLD by the applicant takes unfair advantage of the distinctive character or the reputation of the objector’s registered or unregistered trademark or service mark (“mark”) or IGO name or acronym (as identified in the treaty establishing the organization), or unjustifiably impairs the distinctive character or the reputation of the objector’s mark or IGO name or acronym, or otherwise creates an impermissible likelihood of confusion between the applied-for gTLD and the objector’s mark or IGO name or acronym.
Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ <image003.png> Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com>
From: Rubens Kuhl [mailto:rubensk@nic.br] Sent: Monday, June 18, 2018 6:06 PM To: Aikman-Scalese, Anne Cc: Rosette, Kristina; gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: Re: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
Anne and Kristina,
While we can reckon the actual standard used in 2012, we can't simply ignore that we have - The current applicable GNSO Recommendation (3) saying infringement - Three AGB references using infringement 3.2.1 Grounds for Objection Legal Rights Objection – The applied-for gTLD string infringes the existing legal rights of the objector. 3.2.2.2 Legal Rights Objection A rightsholder has standing to file a legal rights objection. The source and documentation of the existing legal rights the objector is claiming (which may include either registered or unregistered trademarks) are infringed by the applied-for gTLD must be included in the filing. Attachment to Module 3 Article 2 (e) (ii) “Existing Legal Rights Objection” refers to the objection that the string comprising the potential new gTLD infringes the existing legal rights of others
(not counting 3.5.2, where infringement is redefined to the criteria actually used)
That means that in order to keep 2012 status-quo, the policy recommendation needs to be changed and AGB also needs to be changed.
What I find curious is that ICANN's own Program Implementation Review failed to acknowledge this deviation from policy, and we probably need to state that somehow. Even if the PDP finds that it was for the better, and it looks that way to me, we shouldn't miss the learning that this mistake provided.
Rubens
On 18 Jun 2018, at 19:07, Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> wrote:
I support Kristina’s comments shown in the attachment and note that she also states in her comment on page 10 that the LRO in 2012 was not an “infringement” standard. Kristina suggests in the attachment that we simply refer to the “standard used in 2012” if we are not willing to set out the three grounds set forth in the AGB and copied again below.
This same reference to “infringement analysis” occurs on page 15 of draft Section 1.8 so the language there should be conformed to the language chosen for page 10.
Again, the standard for LRO from 2012 is as follows:
As provided for in section 3.5.2 of the ICANN Applicant Guidebook, the independent panel will determine whether the potential use of the applied-for gTLD by the applicant: (i) takes unfair advantage of the distinctive character or the reputation of the objector’s registered or unregistered trademark or service mark (“mark”) or IGO name or acronym, or (ii) unjustifiably impairs the distinctive character or the reputation of the objector’s mark or IGO name or acronym, or (iii) otherwise creates an impermissible likelihood of confusion between the applied-for gTLD and the objector’s mark or IGO name or acronym.
Anne
Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ <image003.png> Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com>
From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Rosette, Kristina via Gnso-newgtld-wg Sent: Monday, June 18, 2018 7:52 AM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: [Gnso-newgtld-wg] FW: Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
This time with attachment. Apologies.
From: Rosette, Kristina Sent: Monday, June 18, 2018 10:51 AM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Cc: 'Steve Chan' <steve.chan@icann.org<mailto:steve.chan@icann.org>> Subject: RE: [Gnso-newgtld-wg] Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
My comments and suggestions on 1.8 attached.
From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces@icann.org] On Behalf Of Steve Chan Sent: Sunday, June 17, 2018 1:25 PM To: gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org> Subject: [Gnso-newgtld-wg] Proposed agenda - New gTLD Subsequent Procedures PDP WG - 18 June 2018 at 15:00 UTC
Dear WG Members,
With apologies for the late delivery, please find the proposed agenda for the New gTLD Subsequent Procedures WG meeting scheduled for 18 June 2018 at 15:00 UTC, for 90 minutes.
• Agenda Review • Roll Call/SOIs • Review of the Initial Report (continued). * The purpose of this review is to ensure that preliminary outcomes and deliberations are accurately captured and written in an understandable manner. The WG Co-Chairs have sought to make clear that this exercise is not intended to re-open substantive discussions, which is better served by the submission of public comments and subsequently when reviewing public comments received. Please submit your comments about these sections to the Working Group mailing list (gnso-newgtld-wg@icann.org<mailto:gnso-newgtld-wg@icann.org>) in advance of the meeting. • Review of Section 1.8 (Accountability Mechanisms) • Review of Section 1.9 (Community Applications) • Review of other sections in the Initial Report • AOB
For Item 3, the relevant documents are attached. As a reminder, please note that a resource page has been set up on the Wiki to track the distribution of Initial Report sections, which you can find here: https://community.icann.org/x/NwUhB.
For Item 4, you will find a draft of most of the other sections within the Initial Report, including the Preamble and the Executive Summary. You will see a placeholder in Section 2, which states, “Insert sections from the excerpts reviewed by Working Group…” – here, staff will insert the sections we have been reviewing for the last couple of months, inclusive of any changes as needed from discussions on calls and on list.
Those signed up as Members to this PDP WG should have received meeting information from the SOAC Support team. If you did not receive these participation details or if you would like to send your apologies, please contact the SOAC Support team (gnso-secs@icann.org<mailto:gnso-secs@icann.org>).
Best, Steve
Steven Chan Policy Director, GNSO Support
ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094-2536 steve.chan@icann.org<mailto:steve.chan@icann.org> mobile: +1.310.339.4410 office tel: +1.310.301.5800 office fax: +1.310.823.8649
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Good Night. I shall read the red lines tomorrow morning. ;-)) CW
El 19 de junio de 2018 a las 20:41 Jeff Neuman <jeff.neuman@comlaude.com> escribió:
Thanks Anne and everyone.
Anne – When you see the redlines today, I think you will find that all of your comments are included.
Everyone else -We understand the views of the group. As previously stated, there is a leadership call in about 8 hours from now. The leadership team includes all of the work track leads and of course we will discuss your views. I do not want to make a unilateral call on this topic because of its importance to the entire leadership team and make sure that the track we choose to go down has full support from the team.
So lack of a response for the next 8 hours does not mean we are ignoring you.
Thanks.
Jeffrey J. Neuman
Senior Vice President |Valideus USA | Com Laude USA
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@Jintlaw
Anne, I'll skip non WT4 themes since they have already been or will be addressed by others.
2. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment.
Actually, it is quite the opposite. What is said there is that applicants would be able to disclose services at application time even if not submitting them to evaluation, increasing opportunity for Objections.
3. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem.
There is a fundamental difference between evaluation processing and results publishing. WT4 only addressed the first part; if a result is ready but due to the application sequencing it's publishing is not yet timely, then it won't be published. The process is not meant to be a waterfall, but a series of parallel efforts that have some control points, and any fairness issue is address at those control points. Rubens
Rubens, See comments inline. If these issues are not raised in the Initial Report, the discussions that occurred in Work Track 4 are not accurately reflected. (See especially the mp3 of the November 30 call and my follow up emails in January and February citing to the exact minute of the mp3 recording.) Anne Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ [cid:image002.png@01D407ED.67209860] Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com/> From: Rubens Kuhl [mailto:rubensk@nic.br] Sent: Tuesday, June 19, 2018 4:16 PM To: Aikman-Scalese, Anne Cc: Jeff Neuman; gnso-newgtld-wg@icann.org Subject: Re: [Gnso-newgtld-wg] New gTLD Subsequent Procedures PDP WG - Initial Report Anne, I'll skip non WT4 themes since they have already been or will be addressed by others. 2. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment. Actually, it is quite the opposite. What is said there is that applicants would be able to disclose services at application time even if not submitting them to evaluation, increasing opportunity for Objections. There is no point in arguing this difference of opinion further. The 2012 round application Question 23 REQUIRES disclosure of all services at the time of application. This is not optional “would be able” disclosure. That’s why the draft does not reflect the discussion in Work Track 4. The draft says it’s optional and does not highlight the issue discussed in Work Track 4 which I have raised and documented multiple times. (No one disagrees with the concept of pre-approved services and no one disagrees as to new services not known at the time of application. We rely on applicants to be honest.) The language I proposed discusses the trade-offs and you know I have raised this issue consistently from the first slide you produced. It was tagged as an issue for public comment and I identified the point in the mp3 from the November 30 call where this was discussed as well as the follow-up email I sent to the list. Failing to reflect this issue in the Initial Report would mean discussion in the Work Track is not accurately reflected. Jeff and Cheryl are very aware of this, having participated in those calls directly and read the corresponding list emails. 3. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem. There is a fundamental difference between evaluation processing and results publishing. WT4 only addressed the first part; if a result is ready but due to the application sequencing it's publishing is not yet timely, then it won't be published. The process is not meant to be a waterfall, but a series of parallel efforts that have some control points, and any fairness issue is address at those control points. I and others expressed concern about the effect of this aggregation on time of processing applications in Work Track 4. The issue was raised as a question for public comment from November 30 onward and was noted as such in the follow-up email I sent to the list, including the exact point in the mp3 of the November 30 call where this was discussed. Failing to reflect that concern would simply be a denial of the discussions that actually occurred in the Work Track. Jeff and Cheryl are very aware of this, having participated in those calls directly and read the corresponding list emails. Rubens ________________________________ This message and any attachments are intended only for the use of the individual or entity to which they are addressed. If the reader of this message or an attachment is not the intended recipient or the employee or agent responsible for delivering the message or attachment to the intended recipient you are hereby notified that any dissemination, distribution or copying of this message or any attachment is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the sender. The information transmitted in this message and any attachments may be privileged, is intended only for the personal and confidential use of the intended recipients, and is covered by the Electronic Communications Privacy Act, 18 U.S.C. §2510-2521.
On 19 Jun 2018, at 20:48, Aikman-Scalese, Anne <AAikman@lrrc.com> wrote:
Rubens,
See comments inline. If these issues are not raised in the Initial Report, the discussions that occurred in Work Track 4 are not accurately reflected. (See especially the mp3 of the November 30 call and my follow up emails in January and February citing to the exact minute of the mp3 recording.)
Anne, while you are focused on the report, I referred to the actual substantive discussions in WT4. I'll let staff and co-chairs answer anything related to the report, which was not the focus of my responses.
2. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment.
Actually, it is quite the opposite. What is said there is that applicants would be able to disclose services at application time even if not submitting them to evaluation, increasing opportunity for Objections. There is no point in arguing this difference of opinion further. The 2012 round application Question 23 REQUIRES disclosure of all services at the time of application. This is not optional “would be able” disclosure. That’s why the draft does not reflect the discussion in Work Track 4.
I mentioned above how the WT4 outcome described how it could be done, not how 2012 round was done, which is only part of the report.
The draft says it’s optional and does not highlight the issue discussed in Work Track 4 which I have raised and documented multiple times.
It's actually silent on that, and others also didn't take that language as saying that, as you probably remember.
3. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem.
There is a fundamental difference between evaluation processing and results publishing. WT4 only addressed the first part; if a result is ready but due to the application sequencing it's publishing is not yet timely, then it won't be published. The process is not meant to be a waterfall, but a series of parallel efforts that have some control points, and any fairness issue is address at those control points. I and others expressed concern about the effect of this aggregation on time of processing applications in Work Track 4.
Actually not; only in Registry Services other have mentioned that, regarding aggregation of evaluations. Rubens
In order to refresh your memory, please see attached email with references to the specific minute of the mp3 recording for each issue. Anne E. Aikman-Scalese Of Counsel 520.629.4428 office 520.879.4725 fax AAikman@lrrc.com<mailto:AAikman@lrrc.com> _____________________________ [cid:image003.png@01D407F1.DD3974F0] Lewis Roca Rothgerber Christie LLP One South Church Avenue, Suite 2000 Tucson, Arizona 85701-1611 lrrc.com<http://lrrc.com/> From: Rubens Kuhl [mailto:rubensk@nic.br] Sent: Tuesday, June 19, 2018 5:14 PM To: Aikman-Scalese, Anne Cc: Jeff Neuman; gnso-newgtld-wg@icann.org Subject: Re: [Gnso-newgtld-wg] New gTLD Subsequent Procedures PDP WG - Initial Report On 19 Jun 2018, at 20:48, Aikman-Scalese, Anne <AAikman@lrrc.com<mailto:AAikman@lrrc.com>> wrote: Rubens, See comments inline. If these issues are not raised in the Initial Report, the discussions that occurred in Work Track 4 are not accurately reflected. (See especially the mp3 of the November 30 call and my follow up emails in January and February citing to the exact minute of the mp3 recording.) Anne, while you are focused on the report, I referred to the actual substantive discussions in WT4. I'll let staff and co-chairs answer anything related to the report, which was not the focus of my responses. 2. Disclosure of New Services at the Time of Application. Regarding the portion of the draft report that deals with disclosure of new services at the time of application, Question 23 of the existing application requires that all new services proposed be described, including any security and stability issues that may be associated with that. The initial draft report skipped over this issue that was clearly raised in Work Track 4 and talked about the flexibility to propose new services either at the application stage or later on in the RSEP process (even if known at the time of application). As mentioned, there are “trade-offs” here in relation to opportunities for Objections and Evaluations and these should be highlighted for public comment. Actually, it is quite the opposite. What is said there is that applicants would be able to disclose services at application time even if not submitting them to evaluation, increasing opportunity for Objections. There is no point in arguing this difference of opinion further. The 2012 round application Question 23 REQUIRES disclosure of all services at the time of application. This is not optional “would be able” disclosure. That’s why the draft does not reflect the discussion in Work Track 4. I mentioned above how the WT4 outcome described how it could be done, not how 2012 round was done, which is only part of the report. The draft says it’s optional and does not highlight the issue discussed in Work Track 4 which I have raised and documented multiple times. It's actually silent on that, and others also didn't take that language as saying that, as you probably remember. 3. Aggregated Technical and Financial Evaluations. There was discussion in Work Track 4 about not putting applications that propose new and innovative services at a disadvantage as to timing of contract award based on the fact that these could not be processed as quickly. The purpose of the new gTLD program is innovation. Again, there are “trade-offs” here. This question falls into the category of items as to which there has been no coordination among the Work Tracks. While this may not have been the responsibility of Work Track 4 per se, that does not mean it is not a concern and does not mean it was not discussed. I am not the only person in the Work Track who mentioned this problem. There is a fundamental difference between evaluation processing and results publishing. WT4 only addressed the first part; if a result is ready but due to the application sequencing it's publishing is not yet timely, then it won't be published. The process is not meant to be a waterfall, but a series of parallel efforts that have some control points, and any fairness issue is address at those control points. I and others expressed concern about the effect of this aggregation on time of processing applications in Work Track 4. Actually not; only in Registry Services other have mentioned that, regarding aggregation of evaluations. Rubens ________________________________ This message and any attachments are intended only for the use of the individual or entity to which they are addressed. If the reader of this message or an attachment is not the intended recipient or the employee or agent responsible for delivering the message or attachment to the intended recipient you are hereby notified that any dissemination, distribution or copying of this message or any attachment is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the sender. The information transmitted in this message and any attachments may be privileged, is intended only for the personal and confidential use of the intended recipients, and is covered by the Electronic Communications Privacy Act, 18 U.S.C. §2510-2521.
participants (4)
-
Aikman-Scalese, Anne -
Jeff Neuman -
lists＠christopherwilkinson.eu Wilkinson -
Rubens Kuhl