Hi everybody, We would like to provide a summary of where we stand concerning the duration of the period of time during which GAC Member Early Warnings, comments, and objections can be filed following String Confirmation Day. Note that, while it would be preferable if these processes had the same duration, it does not necessarily have to be the case. We note that there may have been some confusion on our end regarding what community members were commenting on, and so going forward we will assume that all three input processes should have the same duration - regardless of where we settle on. With that, here is our recap of where we stand/how we got here: ICANN initially proposed that this period, which includes GAC Member Early Warnings, objections, and application comments, will be 90 days following String Confirmation Day, and no public comments were received concerning the proposed duration in the Third Proceeding for Proposed Language for Draft Sections of Next Round AGB<https://www.icann.org/en/public-comment/proceeding/third-proceeding-for-prop...>. Subsequently, Justine proposed to extend this period to 135 days on 6 May 2025<https://lists.icann.org/hyperkitty/list/subpro-irt@icann.org/thread/YZXNT23F...>. Marc expressed support, and Jeff raised concerns. The ALAC subsequently submitted a public comment<https://www.icann.org/en/public-comment/proceeding/final-proceeding-for-prop...> with the same request, as suggested by ICANN, as part of the Final Proceeding for Proposed Language for the Draft Next Round Applicant Guidebook<https://www.icann.org/en/public-comment/proceeding/final-proceeding-for-prop...>. The issue was then discussed with the IRT during meeting #151<https://icann-community.atlassian.net/wiki/x/AYCOEw>. Kathy and Juan expressed strong support for an extension, Phil did not object to adding more time. Jeff, Elaine, and Katrin indicated that they would rather not make any changes, pointing to the implicit extension of the applicant journey if this period were to be extended. Following ICANN’s request<https://lists.icann.org/hyperkitty/list/subpro-irt@icann.org/thread/RHTSBHQ4...> to the group to share their thoughts on-list, Anne suggested a compromise solution of extending the period by 14 days, which found Katrin’s, Jeff’s, and Mike’s opposition, and Marc’s and Karen’s support/non-opposition. During meeting meeting #155<https://icann-community.atlassian.net/wiki/x/KQCOEw>, Kathy and Juan reiterated their support for ALAC’s proposal. In the same email thread<https://lists.icann.org/hyperkitty/list/subpro-irt@icann.org/thread/RHTSBHQ4...>, Justine then indicated that the compromise solution put forward by Anne of 104 days would still not be sufficient for the ALAC, which would need at least 120 days. As there is no clear consensus for any one solution, it seems to us that the middle ground, i.e. Anne’s proposal of 104 days, could be the way forward, noting the limited impact on the processing timeline. Should we have missed or misinterpreted any of the input received, or should you have any additional thoughts, please respond on list. Thank you! Elisa From: Justine Chew <justine.chew.icann@gmail.com> Date: Wednesday, 27 August 2025 at 18:16 To: Elisa Busetto <elisa.busetto@icann.org> Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org> Subject: Re: [Ext] Re: [SubPro-IRT] Re: Length of the Objection Period Hi Elisa, I'm not sure I understand your question. Even though I referred only to objections, as I understand it, the comment period and objection period are concurrent, are they not? The ALAC processes I speak of have been designed for both, they are called the ALAC Procedure for Filing Comments and Objections. Kind regards, Justine --------- On Thu, 28 Aug 2025, 00:05 Elisa Busetto, <elisa.busetto@icann.org<mailto:elisa.busetto@icann.org>> wrote: Hi Justine, Thanks for getting back to us on this. Just to confirm: Does this apply to objections only? Would it work for the ALAC to have 90 or 104 days to submit comments? I’m asking since in the public comment submitted to the ALAC the request was to extend the ‘Community Input and Objection period’ – which includes application comments. Thank you so much, Elisa P.S. @Jeff, we will look again at all the feedback received and provide more context tomorrow. Thanks for your patience. From: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Date: Wednesday, 27 August 2025 at 17:41 To: Elisa Busetto <elisa.busetto@icann.org<mailto:elisa.busetto@icann.org>> Cc: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Subject: [Ext] Re: [SubPro-IRT] Re: Length of the Objection Period Hi Elisa, All, I have to ask for reconsideration for more time for the community to prepare for objections. If 135 days cannot be accommodated, then the ALAC/At-Large asks for 120 days (instead of 90 days) as we are really constrained to comply with our bottom-up process as a condition for ICANN funding for objections. I hope everyone can appreciate that having to shrink the period for our 3-level objection development and approval processes from something like 7 months (in the 2012 round) to 104 days is extremely challenging, to say the least. I do not know if other groups have similar approval processes for developing their objections but the ALAC certainly does and to force the ALAC/At-Large community to accommodate 104 days can be argued as paying mere lip service to the multistakeholder model that ICANN claims to be. Kind regards, Justine On Tue, 26 Aug 2025 at 17:30, Elisa Busetto via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Hi all, As discussed during meeting #155 [icann-community.atlassian.net]<https://urldefense.com/v3/__https:/icann-community.atlassian.net/wiki/x/KQCO...>, ICANN agrees with the proposal to extend the period of time during which application comments can be submitted (and shared with evaluators – the ACF will stay open), objections filed, and Early Warnings issued from 90 to 104 days – which will add 14 days to the overall application processing time to ensure that evaluators have the opportunity to consider the comments received in their evaluation. Unless a different consensus emerges on the mailing list, we will adjust the AGB language and our processes accordingly. Thank you all for your input! Elisa From: trachtenbergm--- via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Reply to: "trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>" <trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>> Date: Thursday, 14 August 2025 at 02:02 To: "mike@rodenbaugh.com<mailto:mike@rodenbaugh.com>" <mike@rodenbaugh.com<mailto:mike@rodenbaugh.com>>, "jeff@jjnsolutions.com<mailto:jeff@jjnsolutions.com>" <jeff@jjnsolutions.com<mailto:jeff@jjnsolutions.com>> Cc: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Subject: [SubPro-IRT] Re: Length of the Objection Period I support Ann and Karen’s comments. Regardless of how long it may currently take to get to delegation in the next round, adding 14 days to accommodate ALAC is not a material difference to anyone’s business plans. Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 360 North Green Street | Suite 1300 | Chicago, IL 60607 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com<https://urldefense.com/v3/__http:/www.gtlaw.com/__;!!PtGJab4!7VIHe8ee-d6EDDB...> [gtlaw.com]<https://urldefense.com/v3/__http:/www.gtlaw.com/__;!!PtGJab4!7VIHe8ee-d6EDDB...> | View GT Biography <https://urldefense.com/v3/__https:/www.gtlaw.com/en/professionals/t/trachten...> [gtlaw.com]<https://urldefense.com/v3/__https:/www.gtlaw.com/en/professionals/t/trachten...> [Greenberg Traurig Logo] From: Mike Rodenbaugh via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Wednesday, August 13, 2025 9:08 AM To: jeff@jjnsolutions.com<mailto:jeff@jjnsolutions.com> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Length of the Objection Period *EXTERNAL TO GT* I support Jeff and Katrin's comments. The process is already egregiously long, and 90 days should be more than enough time to prepare an objection. [Logo] Mike Rodenbaugh Rodenbaugh Law LLC email: mike@rodenbaugh.com<mailto:mike@rodenbaugh.com> phone: +1 (415) 738-8087 On Wed, Aug 13, 2025 at 9:50 AM jeff--- via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: All, As explained during the meeting, I am opposed to extending the length of the objection period. We already have a situation where the soonest a TLD can be delegated is at least 15-18 months depending on when you measure the "start date". And that is only if there are no objections, RVCs, contention, Name Collision issues, Not geographic, no GAC advice AND the application is very early in the priority draw. To put that into more perspective, if the window opens April 30, 2026, the soonest it could be delegated is August or September 2027! That would be 14 years after the first TLD was delegated in the last round (August 2013). And dont forget that delegation does not = launch of a TLD. That is just the start before you have to announce your Sunrise, conduct your Sunrise, etc....realistically meaning that the first TLD to actually be in steady state no earlier than January 2028. The point is that if we add 45 more days to the objection period, that changes the equation to have the soonest a TLD can be delegated to 16.5 - 19.5 months....again that is BEST CASE Scenario with no contention, etc. And of course that pushes everything else out. We should all be making efforts to figure out how to reduce the time and not adding IMHO. Sincerely, Jeff [cid:ii_198ec48a0ce692e333] On 8/13/2025 9:27:17 AM, Katrin Ohlmer | DOTZON GmbH via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear All, the objection period is designed to accommodate input from all parties, including applicants, companies, governments, and ICANN stakeholder groups. So applications (and potential objections) have to be consideres sometimes by larger groups of people, sometimes by individuals representing an applicant or a government. And while I understand the notion of having more time to review applications and consider objections, smaller entities with less resources have not asked for an extension of the period, knowing that this phase will be a very busy and demanding period. So in balance between the need for thorough review and request for expedited evaluation, I think that retaining the current 90-day period is appropriate. Best regards, Katrin DOTZON GmbH – creating identities Akazienstrasse 28 10823 Berlin Deutschland - Germany Mobile: +49 173 2019240 ohlmer@dotzon.consulting<mailto:ohlmer@dotzon.consulting> www.dotzon.consulting<https://urldefense.com/v3/__http:/www.dotzon.consulting/__;!!DUT_TFPxUQ!A3gy...> DOTZON GmbH Registergericht: Amtsgericht Berlin-Charlottenburg, HRB 118598 Geschäftsführer: Katrin Ohlmer Sitz der Gesellschaft: Akazienstrasse 28, 10823 Berlin Von: Anne ICANN via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Gesendet: Mittwoch, 13. August 2025 01:20 An: Lars Hoffmann <lars.hoffmann@icann.org<mailto:lars.hoffmann@icann.org>> Cc: Juan Manuel Rojas via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Betreff: [SubPro-IRT] Re: Length of the Objection Period Hi Lars, As I understand it, the period between Reveal Day and String Confirmation Day is 14 days. The current 90 day Objection period runs from String Confirmation Day, so assuming that not all strings will change in that period, an overview can be conducted to classify strings that may be objectionable or require comment so that the initial review period is actually closer to 104 days from String Confirmation Day. The ALAC has asked for 135 days from String Confirmation Day due to its commitment to review applications on all regional levels. I have the following two comments: 1. PROCEDURAL: If, in the previous IRT meetings discussing this topic, the IRT determined the period should be 90 days after full discussion, then it should be 90 days. However, today's discussion leads me to believe this was not fully decided previously and Justine has noted that the "90" was always in brackets. If staff has reviewed this discussion in the recordings and determined the issue was already decided by the IRT, that is one scenario. If that is not the case, then one would have to conclude that the IRT is deciding this now and that is why you have put it out on the list for discussion. IF THIS IS WRONG, PLEASE ADVISE. 2. SUBSTANTIVE: If the question was not previously decided in a definitive manner, I think it makes sense for the IRT to compromise and respond to the ALAC request with an additional 14 days (not an additional 45 days) so that the Objection period runs 104 days from String Confirmation Day. To me, a small compromise makes sense if the issue was not previously decided. Everyone would then have 118 days TOTAL to review and classify but watching for any changes to strings that occur on String Confirmation Day. (Apologies for any confusion I created when I said we should "give the ALAC" some middle ground solution - of course I meant everyone - not just the ALAC.) Based on today's recording, I know Jeff and others will oppose this idea, but I don't think it's fair to recite that the ALAC access to the Objection process was "controversial". That isn't relevant because it's clear ALAC does have Objection access under the policy. It's also clear that the regional approval process to which ALAC has committed is more complicated, especially where Objection filing is concerned. If ALAC Leadership proposes Objection filing as to a particular string, it's reasonable to think it would take 14 days to (1) get approval from regional bodies to file and (2) get review of a draft filing from the regional bodies and finalize it. Anne Anne Aikman-Scalese GNSO Councilor NomCom Non-Voting 2022-2026 anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com> On Tue, Aug 12, 2025 at 7:44 AM Lars Hoffmann via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear IRT. We had a spirited discussion on the length of the community input period. Please review the recording [icann.zoom.us]<https://urldefense.com/v3/__https:/icann.zoom.us/rec/share/LIXUI8TxusG8h4ukt...> and chat (attached) if you could not join the call. As discussed, we would like to encourage an on-list discussion whether the 90-day objection filing period should be extended to 135 days, which will directly impact the length of the applicant journey. Please refer to the Draft AGB (p.47)<https://urldefense.com/v3/__https:/itp.cdn.icann.org/en/files/policy-develop...> for the current estimate of the length of the shortest possible applicant journey from submission to delegation. We would kindly invite you to share your thoughts on list. Best. 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