Hi Justine, Thank you very much for your kind words and for reviewing the language. Please see below our responses to your comments. *** Community Input Window The ALAC requests consideration for extending this time period to 135 days. The ALAC believes 135 days is a more reasonable time period for purposes of application comments and/or objections given the time needed to review the anticipated high number of applications (which org have factored into its calculation of fees), while still meeting the rigorous stipulations for its process for objections -- i.e. requiring bottom-up development of potential objections, discussion and approval of objections at the RALO level, and followed by a process for ALAC's consideration and approval of the objection. The ALAC raises a valid point, but we would like to note that this issue was not raised previously as part of IRT discussions or public comments and is not based on any specific policy recommendations. In this context, we would like to invite the ALAC to submit their request as a public comment in the upcoming proceeding, so it can be reviewed by/with the group as part of the discussions on the final updates to the language. We would need some time to assess the exact impact of such a change on processing times, vendor costs, and any other aspects of the Program but would like to provide our initial thoughts below. Firstly, it should be noted that the community may begin reviewing applications and strings on Reveal Day, approximately 16-17 days prior to the comment and the objection periods opening on String Confirmation Day. In other words, the community will have approximately 106-107 days to review applications and strings. In addition, it is expected that such a change will extend the overall Program timeline by at least 45 days (the additional time requested by the ALAC) or possibly more. Among others, application comments will be provided to the relevant panels after the comment period closes, which will have an impact on the timeline of the String Evaluation Reports publication. *** Independent Objector I vaguely recall the IRT discussing the possibility of granting the IO a short extension of time beyond the set period to file objections but I don't recall if there was strong support either ways. I'd like to bring up this suggestion again given that the IO's ability to file an objection is dependent on the availability of a comment in opposition having been submitted. Such a comment could foreseeably be submitted at the end of the set period which does not give the IO reasonable time to react to it. We suggested having a separate window for Independent Objectors during meeting #63<https://community.icann.org/x/UgDyF>, and the group seemed to favor having them file objections at the same time as everybody else. Also in this case, we would like to invite the ALAC to submit a public comment so this potential amendment can be discussed with the IRT after the proceeding. *** We welcome any reactions from IRT members on these matters already at this stage but will most likely not be able to make substantive changes to the language before the closing of the final public comment. Best regards, Elisa From: Justine Chew via SubPro-IRT <subpro-irt@icann.org> Reply to: Justine Chew <justine.chew.icann@gmail.com> Date: Tuesday, 6 May 2025 at 12:34 To: Lars Hoffmann <lars.hoffmann@icann.org> Cc: "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Dear Lars, You and your team have been excellent in making sure new comments are noted and reviewed. I would just like to mention that I have made two new comments for this topics(s), one on behalf of the ALAC and the other in my own capacity. Thanks. Kind regards, Justine --------- On Tue, 29 Apr 2025, 18:58 Lars Hoffmann via SubPro-IRT, <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear IRT members, Please see here the redline for the Community Input and Dispute Resolution language: https://docs.google.com/document/d/16HK37AMl3VtfmhzPSoiidyqMYRrKzNRCYArbp7Az... [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/16HK37AMl3Vtfm...> Please note, this topic includes language on: * Application Comments * GAC early warning * GAC advice * Singular/Plural notification * Objections * Standing * Filing and Processing * Appeals If you’d like to provide further input, please use the comment function on the google document. At this time, we have not more discussion on this topic scheduled. Very best. Lars _______________________________________________ SubPro-IRT mailing list -- subpro-irt@icann.org<mailto:subpro-irt@icann.org> To unsubscribe send an email to subpro-irt-leave@icann.org<mailto:subpro-irt-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.

Jeff, I think you may be mischaracterizing both ALAC’s request and Elisa’s response. It doesn’t seems like ALAC is asking for an extension just for them, but for everyone to be able to comment in light of the high number of anticipated applications. I also didn’t read Elisa’s response as saying that she/staff didn’t agree with the request. In fact, Elisa said that the ALAC raised a valid point but that the impact needed more study and they should submit the request as a public comment. At the end of the day I guess the question is whether we feel there is value on people in the community (the ICANN bubble community and also the real internet community that goes beyond the industry players) being able to make public comments on submitted applications. I have heard repeatedly during this process how important it is for the community (however you may define/view it) to make public comments about applications they are concerned about. If that is the case, and it is viewed as important then the next question is whether we want to prioritize speed to delegation over the ability of the community to comment on applications they may have concerns about. If we prioritize the latter, then based on the number of anticipated applications, and how much time would be needed to review them by people in the community based on sheer volume of applications as well as processes for getting to consensus on objections, then a little more time seems reasonable. Best regards, Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com<http://www.gtlaw.com/>  |  View GT Biography <https://www.gtlaw.com/en/professionals/t/trachtenberg-marc-h> [Greenberg Traurig Logo] [US News Law Firm of the Year 2020 and 2022 for Trademark Law badge] From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org> Sent: Thursday, May 8, 2025 10:09 PM To: Elisa Busetto <elisa.busetto@icann.org>; Justine Chew <justine.chew.icann@gmail.com> Cc: subpro-irt@icann.org Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution *EXTERNAL TO GT* Elisa, I. ALAC Request for additional time I agree with your response on not affording the ALAC any additional time to file comments. We are already dealing with the shortest time from application window closing to delegation being around 18 months (in the ideal case) – which is too long to begin with. Remember that all Cs and SGs, not to mention the GAC, face internal issues with getting bottom up advice / comments. And we can’t forget that the Applicant is given some time to respond to comments filed. So if you gave the ALAC an extra 45 days, you would then need to add at least 7 days on top of that for the applicant to respond. So, 45 days essentially turns into 2 months. II. Independent Objector On the Independent Objector, I believe the time period for objections was discussed, but there was not support to increase that time frame beyond the normal objection period. However, that being said, it may make some sense to have the objection period for the IO only perhaps extend a week or two longer than the comment period simply because in order for the IO to file an objection, there needs to be at least one comment filed. In addition, the IO is not supposed to file an objection if there has already been an objection filed on the same grounds. Therefore, giving a SHORT extension of a week or two beyond the objection period may make some sense. Again, that would be for the IO only because of its unique status and because there has to be a comment during the comment period. [cid:image005.png@01DBC070.708DC150] From: Elisa Busetto via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Thursday, May 8, 2025 10:47 PM To: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Hi Justine, Thank you very much for your kind words and for reviewing the language. Please see below our responses to your comments. *** Community Input Window The ALAC requests consideration for extending this time period to 135 days. The ALAC believes 135 days is a more reasonable time period for purposes of application comments and/or objections given the time needed to review the anticipated high number of applications (which org have factored into its calculation of fees), while still meeting the rigorous stipulations for its process for objections -- i.e. requiring bottom-up development of potential objections, discussion and approval of objections at the RALO level, and followed by a process for ALAC's consideration and approval of the objection. The ALAC raises a valid point, but we would like to note that this issue was not raised previously as part of IRT discussions or public comments and is not based on any specific policy recommendations. In this context, we would like to invite the ALAC to submit their request as a public comment in the upcoming proceeding, so it can be reviewed by/with the group as part of the discussions on the final updates to the language. We would need some time to assess the exact impact of such a change on processing times, vendor costs, and any other aspects of the Program but would like to provide our initial thoughts below. Firstly, it should be noted that the community may begin reviewing applications and strings on Reveal Day, approximately 16-17 days prior to the comment and the objection periods opening on String Confirmation Day. In other words, the community will have approximately 106-107 days to review applications and strings. In addition, it is expected that such a change will extend the overall Program timeline by at least 45 days (the additional time requested by the ALAC) or possibly more. Among others, application comments will be provided to the relevant panels after the comment period closes, which will have an impact on the timeline of the String Evaluation Reports publication. *** Independent Objector I vaguely recall the IRT discussing the possibility of granting the IO a short extension of time beyond the set period to file objections but I don't recall if there was strong support either ways. I'd like to bring up this suggestion again given that the IO's ability to file an objection is dependent on the availability of a comment in opposition having been submitted. Such a comment could foreseeably be submitted at the end of the set period which does not give the IO reasonable time to react to it. We suggested having a separate window for Independent Objectors during meeting #63<https://urldefense.com/v3/__https:/community.icann.org/x/UgDyF__;!!DUT_TFPxU...>, and the group seemed to favor having them file objections at the same time as everybody else. Also in this case, we would like to invite the ALAC to submit a public comment so this potential amendment can be discussed with the IRT after the proceeding. *** We welcome any reactions from IRT members on these matters already at this stage but will most likely not be able to make substantive changes to the language before the closing of the final public comment. Best regards, Elisa From: Justine Chew via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Reply to: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Date: Tuesday, 6 May 2025 at 12:34 To: Lars Hoffmann <lars.hoffmann@icann.org<mailto:lars.hoffmann@icann.org>> Cc: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Dear Lars, You and your team have been excellent in making sure new comments are noted and reviewed. I would just like to mention that I have made two new comments for this topics(s), one on behalf of the ALAC and the other in my own capacity. Thanks. Kind regards, Justine --------- On Tue, 29 Apr 2025, 18:58 Lars Hoffmann via SubPro-IRT, <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear IRT members, Please see here the redline for the Community Input and Dispute Resolution language: https://docs.google.com/document/d/16HK37AMl3VtfmhzPSoiidyqMYRrKzNRCYArbp7Az... [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/16HK37AMl3Vtfm...> Please note, this topic includes language on: * Application Comments * GAC early warning * GAC advice * Singular/Plural notification * Objections * Standing * Filing and Processing * Appeals If you’d like to provide further input, please use the comment function on the google document. At this time, we have not more discussion on this topic scheduled. Very best. 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Dear Justine, everybody, We have updated the language concerning funding possibilities for the ALAC and national governments to include the link to the ALAC procedure and clarify what such funding covers. We hope this addresses your concern. To support the multistakeholder model, ICANN offers certain funding possibilities to the At-Large Advisory Committee (ALAC) and national governments, as described below. Such funding is to cover costs payable to the DRSP and made directly to the DRSP, i.e. filing fees and advance payment of costs, as described in [Objections and Appeals Costs]; it does not cover other costs such as fees for legal advice. More information will be published on [this page]. * Funding for ALAC is contingent on publication by ALAC of its approved process for considering and making objections. At a minimum, the process for objecting to a gTLD application will require: * bottom-up development of potential objections, * discussion and approval of objections at the Regional At-Large Organization (RALO) level, and * a process for consideration and approval of the objection by the At-Large Advisory Committee. The ALAC Procedure for Filing Comments and Objections in the New gTLD Program Next Round can be found at https://icann-community.atlassian.net/wiki/x/DwBAD. * Funding from ICANN is available to individual national governments in the amount of USD 50,000 with the guarantee that a minimum of one objection and appeal per government will be fully funded by ICANN where requested. Concerning the duration of the comment and objection periods, as well as the possibility of giving the IO additional time to file objections, we invite you to raise these concerns as part the public comment due to launch on 30 May so we can have more substantive discussions during the final review of the AGB. Thank you! Elisa From: Justine Chew <justine.chew.icann@gmail.com> Date: Monday, 12 May 2025 at 06:16 To: "subpro-irt@icann.org" <subpro-irt@icann.org> Cc: "trachtenbergm@gtlaw.com" <trachtenbergm@gtlaw.com>, "Jeff@jjnsolutions.com" <Jeff@jjnsolutions.com>, Elisa Busetto <elisa.busetto@icann.org> Subject: [Ext] Re: [SubPro-IRT] Re: Community Input & Dispute Resolution Thanks, Elisa for drawing the IRT's attention to my comments (I would have put them in the body of an email save that I was complying with Lar's original request to comments to be made to the relevant googledoc copy) Thanks also to Marc and Jeff, for your comments. All, 1. Marc is correct in that the ALAC isn't asking for an extension of the application comment period to 135 days just for them. Whatever duration is set for the application comment period would - with a possible exception to IOs (to be discussed) - apply to anyone and everyone. What the ALAC is saying is that the anticipated high number of applications for the next round (which ICANN org themselves are contemplating and factoring into their calculation of fees) calls for a reasonable time for the ICANN community and the public to review and react to the same, for the purpose of determining whether or not to submit application comments, and/or to file objections against, and if yes, to go on to do so. 2. To Jeff's point - I will refrain from commenting on the GAC's or Cs and SGs' "approval processes" but I imagine that only the ALAC's preparation of comments and objections would need to undergo three levels of "approvals": (i) bottom-up, i.e. At-Large community members (ii) 5 RALOs, and lastly (iii) the ALAC, the series or sequence of which requires reasonable time to facilitate. The ALAC has acknowledged that funding for the ALAC to file objections is contingent on there being these 3 levels of "approvals" and have prepared the attached document which I am now able to share with the IRT. 3. Regarding the time period for IOs, I think some leeway should be afforded to the IOs, to give them a bit of extra time to file objections because as Jeff and I noted, the IO's ability to file an objection is contingent on there being an unfavorable application comment submitted. In the event such comment is submitted at the 11th hour, the IO will have little to no time to consider and react to the same. Kind regards, Justine On Fri, 9 May 2025 at 12:27, <trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>> wrote: Jeff, I think you may be mischaracterizing both ALAC’s request and Elisa’s response. It doesn’t seems like ALAC is asking for an extension just for them, but for everyone to be able to comment in light of the high number of anticipated applications. I also didn’t read Elisa’s response as saying that she/staff didn’t agree with the request. In fact, Elisa said that the ALAC raised a valid point but that the impact needed more study and they should submit the request as a public comment. At the end of the day I guess the question is whether we feel there is value on people in the community (the ICANN bubble community and also the real internet community that goes beyond the industry players) being able to make public comments on submitted applications. I have heard repeatedly during this process how important it is for the community (however you may define/view it) to make public comments about applications they are concerned about. If that is the case, and it is viewed as important then the next question is whether we want to prioritize speed to delegation over the ability of the community to comment on applications they may have concerns about. If we prioritize the latter, then based on the number of anticipated applications, and how much time would be needed to review them by people in the community based on sheer volume of applications as well as processes for getting to consensus on objections, then a little more time seems reasonable. Best regards, Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com [gtlaw.com]<https://urldefense.com/v3/__http:/www.gtlaw.com/__;!!PtGJab4!-vjHWUxRYfoxbcx...>  |  View GT Biography [gtlaw.com]<https://urldefense.com/v3/__https:/www.gtlaw.com/en/professionals/t/trachten...> [Greenberg Traurig Logo] [US News Law Firm of the Year 2020 and 2022 for Trademark Law badge] From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Thursday, May 8, 2025 10:09 PM To: Elisa Busetto <elisa.busetto@icann.org<mailto:elisa.busetto@icann.org>>; Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution *EXTERNAL TO GT* Elisa, I. ALAC Request for additional time I agree with your response on not affording the ALAC any additional time to file comments. We are already dealing with the shortest time from application window closing to delegation being around 18 months (in the ideal case) – which is too long to begin with. Remember that all Cs and SGs, not to mention the GAC, face internal issues with getting bottom up advice / comments. And we can’t forget that the Applicant is given some time to respond to comments filed. So if you gave the ALAC an extra 45 days, you would then need to add at least 7 days on top of that for the applicant to respond. So, 45 days essentially turns into 2 months. II. Independent Objector On the Independent Objector, I believe the time period for objections was discussed, but there was not support to increase that time frame beyond the normal objection period. However, that being said, it may make some sense to have the objection period for the IO only perhaps extend a week or two longer than the comment period simply because in order for the IO to file an objection, there needs to be at least one comment filed. In addition, the IO is not supposed to file an objection if there has already been an objection filed on the same grounds. Therefore, giving a SHORT extension of a week or two beyond the objection period may make some sense. Again, that would be for the IO only because of its unique status and because there has to be a comment during the comment period. [cid:image003.png@01DBC4C4.A794C2E0] From: Elisa Busetto via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Thursday, May 8, 2025 10:47 PM To: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Hi Justine, Thank you very much for your kind words and for reviewing the language. Please see below our responses to your comments. *** Community Input Window The ALAC requests consideration for extending this time period to 135 days. The ALAC believes 135 days is a more reasonable time period for purposes of application comments and/or objections given the time needed to review the anticipated high number of applications (which org have factored into its calculation of fees), while still meeting the rigorous stipulations for its process for objections -- i.e. requiring bottom-up development of potential objections, discussion and approval of objections at the RALO level, and followed by a process for ALAC's consideration and approval of the objection. The ALAC raises a valid point, but we would like to note that this issue was not raised previously as part of IRT discussions or public comments and is not based on any specific policy recommendations. In this context, we would like to invite the ALAC to submit their request as a public comment in the upcoming proceeding, so it can be reviewed by/with the group as part of the discussions on the final updates to the language. We would need some time to assess the exact impact of such a change on processing times, vendor costs, and any other aspects of the Program but would like to provide our initial thoughts below. Firstly, it should be noted that the community may begin reviewing applications and strings on Reveal Day, approximately 16-17 days prior to the comment and the objection periods opening on String Confirmation Day. In other words, the community will have approximately 106-107 days to review applications and strings. In addition, it is expected that such a change will extend the overall Program timeline by at least 45 days (the additional time requested by the ALAC) or possibly more. Among others, application comments will be provided to the relevant panels after the comment period closes, which will have an impact on the timeline of the String Evaluation Reports publication. *** Independent Objector I vaguely recall the IRT discussing the possibility of granting the IO a short extension of time beyond the set period to file objections but I don't recall if there was strong support either ways. I'd like to bring up this suggestion again given that the IO's ability to file an objection is dependent on the availability of a comment in opposition having been submitted. Such a comment could foreseeably be submitted at the end of the set period which does not give the IO reasonable time to react to it. We suggested having a separate window for Independent Objectors during meeting #63<https://urldefense.com/v3/__https:/community.icann.org/x/UgDyF__;!!DUT_TFPxU...>, and the group seemed to favor having them file objections at the same time as everybody else. Also in this case, we would like to invite the ALAC to submit a public comment so this potential amendment can be discussed with the IRT after the proceeding. *** We welcome any reactions from IRT members on these matters already at this stage but will most likely not be able to make substantive changes to the language before the closing of the final public comment. Best regards, Elisa From: Justine Chew via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Reply to: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Date: Tuesday, 6 May 2025 at 12:34 To: Lars Hoffmann <lars.hoffmann@icann.org<mailto:lars.hoffmann@icann.org>> Cc: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Dear Lars, You and your team have been excellent in making sure new comments are noted and reviewed. I would just like to mention that I have made two new comments for this topics(s), one on behalf of the ALAC and the other in my own capacity. Thanks. Kind regards, Justine --------- On Tue, 29 Apr 2025, 18:58 Lars Hoffmann via SubPro-IRT, <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear IRT members, Please see here the redline for the Community Input and Dispute Resolution language: https://docs.google.com/document/d/16HK37AMl3VtfmhzPSoiidyqMYRrKzNRCYArbp7Az... [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/16HK37AMl3Vtfm...> Please note, this topic includes language on: * Application Comments * GAC early warning * GAC advice * Singular/Plural notification * Objections * Standing * Filing and Processing * Appeals If you’d like to provide further input, please use the comment function on the google document. At this time, we have not more discussion on this topic scheduled. Very best. 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Hi Anne, Thanks for your email. This is ultimately a question for the ALAC – the language very much reflects that in the 2012 AGB, and there was no policy saying that ICANN should do otherwise: Funding available from ICANN is to cover costs payable to the dispute resolution service provider and made directly to the dispute resolution service provider; it does not cover other costs such as fees for legal advice. If there is a desire in the community to provide additional assistance to the ALAC, then this would likely require new policy development. Best, Elisa From: Anne ICANN <anneicanngnso@gmail.com> Date: Wednesday, 14 May 2025 at 17:34 To: Elisa Busetto <elisa.busetto@icann.org> Cc: Justine Chew <justine.chew.icann@gmail.com>, "subpro-irt@icann.org" <subpro-irt@icann.org> Subject: Re: [SubPro-IRT] Re: [Ext] Re: Re: Community Input & Dispute Resolution Thanks Elisa. How does ALAC pay for legal fees when its members authorize filing an Objection if they are excluded from ICANN assistance? Anne Anne Aikman-Scalese GNSO Councilor NomCom Non-Voting 2022-2026 anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com> On Wed, May 14, 2025 at 2:38 AM Elisa Busetto via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear Justine, everybody, We have updated the language concerning funding possibilities for the ALAC and national governments to include the link to the ALAC procedure and clarify what such funding covers. We hope this addresses your concern. To support the multistakeholder model, ICANN offers certain funding possibilities to the At-Large Advisory Committee (ALAC) and national governments, as described below. Such funding is to cover costs payable to the DRSP and made directly to the DRSP, i.e. filing fees and advance payment of costs, as described in [Objections and Appeals Costs]; it does not cover other costs such as fees for legal advice. More information will be published on [this page]. * Funding for ALAC is contingent on publication by ALAC of its approved process for considering and making objections. At a minimum, the process for objecting to a gTLD application will require: * bottom-up development of potential objections, * discussion and approval of objections at the Regional At-Large Organization (RALO) level, and * a process for consideration and approval of the objection by the At-Large Advisory Committee. The ALAC Procedure for Filing Comments and Objections in the New gTLD Program Next Round can be found at https://icann-community.atlassian.net/wiki/x/DwBAD [icann-community.atlassian.net]<https://urldefense.com/v3/__https:/icann-community.atlassian.net/wiki/x/DwBA...>. * Funding from ICANN is available to individual national governments in the amount of USD 50,000 with the guarantee that a minimum of one objection and appeal per government will be fully funded by ICANN where requested. Concerning the duration of the comment and objection periods, as well as the possibility of giving the IO additional time to file objections, we invite you to raise these concerns as part the public comment due to launch on 30 May so we can have more substantive discussions during the final review of the AGB. Thank you! Elisa From: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Date: Monday, 12 May 2025 at 06:16 To: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Cc: "trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>" <trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>>, "Jeff@jjnsolutions.com<mailto:Jeff@jjnsolutions.com>" <Jeff@jjnsolutions.com<mailto:Jeff@jjnsolutions.com>>, Elisa Busetto <elisa.busetto@icann.org<mailto:elisa.busetto@icann.org>> Subject: [Ext] Re: [SubPro-IRT] Re: Community Input & Dispute Resolution Thanks, Elisa for drawing the IRT's attention to my comments (I would have put them in the body of an email save that I was complying with Lar's original request to comments to be made to the relevant googledoc copy) Thanks also to Marc and Jeff, for your comments. All, 1. Marc is correct in that the ALAC isn't asking for an extension of the application comment period to 135 days just for them. Whatever duration is set for the application comment period would - with a possible exception to IOs (to be discussed) - apply to anyone and everyone. What the ALAC is saying is that the anticipated high number of applications for the next round (which ICANN org themselves are contemplating and factoring into their calculation of fees) calls for a reasonable time for the ICANN community and the public to review and react to the same, for the purpose of determining whether or not to submit application comments, and/or to file objections against, and if yes, to go on to do so. 2. To Jeff's point - I will refrain from commenting on the GAC's or Cs and SGs' "approval processes" but I imagine that only the ALAC's preparation of comments and objections would need to undergo three levels of "approvals": (i) bottom-up, i.e. At-Large community members (ii) 5 RALOs, and lastly (iii) the ALAC, the series or sequence of which requires reasonable time to facilitate. The ALAC has acknowledged that funding for the ALAC to file objections is contingent on there being these 3 levels of "approvals" and have prepared the attached document which I am now able to share with the IRT. 3. Regarding the time period for IOs, I think some leeway should be afforded to the IOs, to give them a bit of extra time to file objections because as Jeff and I noted, the IO's ability to file an objection is contingent on there being an unfavorable application comment submitted. In the event such comment is submitted at the 11th hour, the IO will have little to no time to consider and react to the same. Kind regards, Justine On Fri, 9 May 2025 at 12:27, <trachtenbergm@gtlaw.com<mailto:trachtenbergm@gtlaw.com>> wrote: Jeff, I think you may be mischaracterizing both ALAC’s request and Elisa’s response. It doesn’t seems like ALAC is asking for an extension just for them, but for everyone to be able to comment in light of the high number of anticipated applications. I also didn’t read Elisa’s response as saying that she/staff didn’t agree with the request. In fact, Elisa said that the ALAC raised a valid point but that the impact needed more study and they should submit the request as a public comment. At the end of the day I guess the question is whether we feel there is value on people in the community (the ICANN bubble community and also the real internet community that goes beyond the industry players) being able to make public comments on submitted applications. I have heard repeatedly during this process how important it is for the community (however you may define/view it) to make public comments about applications they are concerned about. If that is the case, and it is viewed as important then the next question is whether we want to prioritize speed to delegation over the ability of the community to comment on applications they may have concerns about. If we prioritize the latter, then based on the number of anticipated applications, and how much time would be needed to review them by people in the community based on sheer volume of applications as well as processes for getting to consensus on objections, then a little more time seems reasonable. Best regards, Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com [gtlaw.com]<https://urldefense.com/v3/__http:/www.gtlaw.com/__;!!PtGJab4!-vjHWUxRYfoxbcx...>  |  View GT Biography [gtlaw.com]<https://urldefense.com/v3/__https:/www.gtlaw.com/en/professionals/t/trachten...> [Greenberg Traurig Logo] [US News Law Firm of the Year 2020 and 2022 for Trademark Law badge] From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Thursday, May 8, 2025 10:09 PM To: Elisa Busetto <elisa.busetto@icann.org<mailto:elisa.busetto@icann.org>>; Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution *EXTERNAL TO GT* Elisa, I. ALAC Request for additional time I agree with your response on not affording the ALAC any additional time to file comments. We are already dealing with the shortest time from application window closing to delegation being around 18 months (in the ideal case) – which is too long to begin with. Remember that all Cs and SGs, not to mention the GAC, face internal issues with getting bottom up advice / comments. And we can’t forget that the Applicant is given some time to respond to comments filed. So if you gave the ALAC an extra 45 days, you would then need to add at least 7 days on top of that for the applicant to respond. So, 45 days essentially turns into 2 months. II. Independent Objector On the Independent Objector, I believe the time period for objections was discussed, but there was not support to increase that time frame beyond the normal objection period. However, that being said, it may make some sense to have the objection period for the IO only perhaps extend a week or two longer than the comment period simply because in order for the IO to file an objection, there needs to be at least one comment filed. In addition, the IO is not supposed to file an objection if there has already been an objection filed on the same grounds. Therefore, giving a SHORT extension of a week or two beyond the objection period may make some sense. Again, that would be for the IO only because of its unique status and because there has to be a comment during the comment period. [cid:image003.png@01DBC5B0.9BEBF610] From: Elisa Busetto via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Sent: Thursday, May 8, 2025 10:47 PM To: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Cc: subpro-irt@icann.org<mailto:subpro-irt@icann.org> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Hi Justine, Thank you very much for your kind words and for reviewing the language. Please see below our responses to your comments. *** Community Input Window The ALAC requests consideration for extending this time period to 135 days. The ALAC believes 135 days is a more reasonable time period for purposes of application comments and/or objections given the time needed to review the anticipated high number of applications (which org have factored into its calculation of fees), while still meeting the rigorous stipulations for its process for objections -- i.e. requiring bottom-up development of potential objections, discussion and approval of objections at the RALO level, and followed by a process for ALAC's consideration and approval of the objection. The ALAC raises a valid point, but we would like to note that this issue was not raised previously as part of IRT discussions or public comments and is not based on any specific policy recommendations. In this context, we would like to invite the ALAC to submit their request as a public comment in the upcoming proceeding, so it can be reviewed by/with the group as part of the discussions on the final updates to the language. We would need some time to assess the exact impact of such a change on processing times, vendor costs, and any other aspects of the Program but would like to provide our initial thoughts below. Firstly, it should be noted that the community may begin reviewing applications and strings on Reveal Day, approximately 16-17 days prior to the comment and the objection periods opening on String Confirmation Day. In other words, the community will have approximately 106-107 days to review applications and strings. In addition, it is expected that such a change will extend the overall Program timeline by at least 45 days (the additional time requested by the ALAC) or possibly more. Among others, application comments will be provided to the relevant panels after the comment period closes, which will have an impact on the timeline of the String Evaluation Reports publication. *** Independent Objector I vaguely recall the IRT discussing the possibility of granting the IO a short extension of time beyond the set period to file objections but I don't recall if there was strong support either ways. I'd like to bring up this suggestion again given that the IO's ability to file an objection is dependent on the availability of a comment in opposition having been submitted. Such a comment could foreseeably be submitted at the end of the set period which does not give the IO reasonable time to react to it. We suggested having a separate window for Independent Objectors during meeting #63<https://urldefense.com/v3/__https:/community.icann.org/x/UgDyF__;!!DUT_TFPxU...>, and the group seemed to favor having them file objections at the same time as everybody else. Also in this case, we would like to invite the ALAC to submit a public comment so this potential amendment can be discussed with the IRT after the proceeding. *** We welcome any reactions from IRT members on these matters already at this stage but will most likely not be able to make substantive changes to the language before the closing of the final public comment. Best regards, Elisa From: Justine Chew via SubPro-IRT <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Reply to: Justine Chew <justine.chew.icann@gmail.com<mailto:justine.chew.icann@gmail.com>> Date: Tuesday, 6 May 2025 at 12:34 To: Lars Hoffmann <lars.hoffmann@icann.org<mailto:lars.hoffmann@icann.org>> Cc: "subpro-irt@icann.org<mailto:subpro-irt@icann.org>" <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> Subject: [SubPro-IRT] Re: Community Input & Dispute Resolution Dear Lars, You and your team have been excellent in making sure new comments are noted and reviewed. I would just like to mention that I have made two new comments for this topics(s), one on behalf of the ALAC and the other in my own capacity. Thanks. Kind regards, Justine --------- On Tue, 29 Apr 2025, 18:58 Lars Hoffmann via SubPro-IRT, <subpro-irt@icann.org<mailto:subpro-irt@icann.org>> wrote: Dear IRT members, Please see here the redline for the Community Input and Dispute Resolution language: https://docs.google.com/document/d/16HK37AMl3VtfmhzPSoiidyqMYRrKzNRCYArbp7Az... [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/16HK37AMl3Vtfm...> Please note, this topic includes language on: * Application Comments * GAC early warning * GAC advice * Singular/Plural notification * Objections * Standing * Filing and Processing * Appeals If you’d like to provide further input, please use the comment function on the google document. At this time, we have not more discussion on this topic scheduled. Very best. 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