Thank you, Paul. Perhaps I work with different contract forms as I've not seen many specific time limitations on addressing disputes (through arbitration or otherwise). On rare occasions I've seen use of terms like "promptly" or "without delay" but not a specified number of months/years. As for this situation, there's no reason why it must differ. I'm simply trying to propose common ground based on existing equitable considerations in the hope that we can reach a consensus and move on to more important issues as per our WG's timeline. Regards, Steve From: "Paul@law.es<mailto:Paul@law.es> ZIMBRA" <paul@law.es<mailto:paul@law.es>> Date: Wednesday, July 20, 2016 at 3:05 PM To: "Steven M. Levy, Esq." <slevy@accentlawgroup.com<mailto:slevy@accentlawgroup.com>> Cc: George Kirikos <icann@leap.com<mailto:icann@leap.com>>, "gnso-rpm-wg@icann.org<mailto:gnso-rpm-wg@icann.org>" <gnso-rpm-wg@icann.org<mailto:gnso-rpm-wg@icann.org>> Subject: Re: [gnso-rpm-wg] PDDRP topics -- limitation period to bring a PDDRP Steve, Admirable comment but you will no doubt note that most contractual,arbitration provisions have a very limited "statute of limitations". Why then must this situation differ? Paul Keating On 20 Jul 2016, at 7:59 PM, Steve Levy <slevy@accentlawgroup.com<mailto:slevy@accentlawgroup.com>> wrote: George, I understand the foundation of your idea - that parties should not have greater rights through the PDDRP than they would in a court of law. But, by the same token, they shouldn't have lesser rights either. As such, I suggest revising your recommendation so that any time limit for bringing a PDDRP claim would be the longer of the applicable statute of limitations for such a claim in the complainant's or respondent's jurisdictions if such claim were to have been brought in the courts. Regards, Steve <Accent Law Logo NEW Very Small[4].png> Steven M. Levy, Esq. Accent Law Group, Inc. 301 Fulton St. Philadelphia, PA 19147 United States Phone: +1-215-327-9094 Email: slevy@AccentLawGroup.com<mailto:slevy@accentlawgroup.com> Website: www.AccentLawGroup.com<http://www.accentlawgroup.com/> <http://www.accentlawgroup.com/>LinkedIn: www.linkedin.com/in/stevelevy43a/<http://www.linkedin.com/in/stevelevy43a/> ________________________________________ Notice: This communication, including attachments, may contain information that is confidential and protected by the attorney/client or other privileges. It constitutes non-public information intended to be conveyed only to the designated recipient(s). If the reader or recipient of this communication is not the intended recipient, an employee or agent of the intended recipient who is responsible for delivering it to the intended recipient, or you believe that you have received this communication in error, please notify the sender immediately by return e-mail and promptly delete this e-mail, including attachments without reading or saving them in any manner. The unauthorized use, dissemination, distribution, or reproduction of this e-mail, including attachments, is prohibited and may be unlawful. Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client or other privilege. On 7/20/16, 1:49 PM, "gnso-rpm-wg-bounces@icann.org<mailto:gnso-rpm-wg-bounces@icann.org> on behalf of George Kirikos" <gnso-rpm-wg-bounces@icann.org<mailto:gnso-rpm-wg-bounces@icann.org> on behalf of icann@leap.com<mailto:icann@leap.com>> wrote: Hi folks, I don't think this was brought up before yet in the context of the PDDRP, but perhaps it can be added to the list of topics. It would be very odd if complainants were allowed to bring a PDDRP for a matter that was not able to be brought by them in a court of law, because it was barred by the relevant statute of limitations. I think amending the PDDRP to explicitly add a time limit for bringing a PDDRP would make sense, to handle this situation. 2 years would be a suitable limit, in my opinion, and would help ensure that complaints are brought in a timely fashion. Thoughts? Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ _______________________________________________ gnso-rpm-wg mailing list gnso-rpm-wg@icann.org<mailto:gnso-rpm-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-rpm-wg _______________________________________________ gnso-rpm-wg mailing list gnso-rpm-wg@icann.org<mailto:gnso-rpm-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-rpm-wg