The comment period for the Phase 1 Initial Report of the Review of All Rights Protection Mechanisms in All gTLDs Policy Development Process ends on May 4, 2020, less than 2 days from now (which is not sufficient time to do a thorough analysis). I have previously written about it (see my prior blog posts here, here, here and here). However, it continues to be fraught with problems.
I sent ICANN staff another email tonight, blasting them for the lack of any common sense in the design of their garbage public comment system. Had they taken my advice and broken it down into “bite sized” segments, they could have had “rolling deadlines”, e.g. answer the first 20 questions by May 4, the next 20 questions by May 11, and so on, until all 192 questions were answered. ICANN staff has ignored me (as they do most concerns of registrants), but I did want to put that “on the record”.
Here’s the complete email I sent to them:
Less than 2 days left, if the deadline isn’t changed ASAP. Here’s the thing which should be obvious, but I’d like to point out “for the record” (complaints office did reply, but no one else has to date).
Had ICANN staff split the gargantuan form into multiple “bite sized” ones, as I suggested, then the Working Group could have set separate deadlines for different sections, i.e. get the first 20 questions done by May 4th, get the next 20 questions done by May 11th, and so on. The working group isn’t even going to likely get around to analyzing comments related to the last 20 questions (there are 192 of them!) until some time in late June, or even beyond…..what’s the point in forcing those submissions to be made by May 4? Everything seems designed to reduce public input, to frustrate and thwart it, rather than to embrace it and encourage it. I’ll be writing about this debacle further, after the deadline, but just wanted this on the record, that you had multiple opportunities to do the “right thing”, but repeatedly chose to do the “wrong thing.”
If ICANN can’t even design a fair or reasonable public comment system, how can they be trusted to design fair rights protection mechanisms, or any other complex systems?