You have until Monday, August 10, 2026 (23:59 UTC) to tell ICANN what you think. Do not miss this deadline. Submit comments here. There will likely be no further opportunity to comment on these changes.
I’ve completed my company’s comments to ICANN regarding their proposed changes to the UDRP and URS. These lopsided changes harm domain name registrants, and do not even faithfully apply the recommendations of the prior policy working groups.
The documents out for public comment are misaligned with the underlying policy recommendations, to the further detriment of registrants’ fundamental rights to due process. ICANN takes every opportunity to hollow out the rights of domain name owners, especially when few are paying attention. The capture of the process is evident, given that the deviations from the policy recommendations are not random, but overwhelmingly go in favour of IGOs (like WIPO, OECD, etc.) and against registrants. The policy recommendations themselves were already unbalanced, and we expressed our opposition repeatedly. But, the implementation of the recommendations is even worse than the policies that the ICANN Board approved.
You can read my company’s full submission in the PDF below (105 pages!), or via ICANN’s public comment forum.
LEAP-ICANN-IGO-2026August9-comments-FINAL.pdf
I sounded the alarm about the serious defects on Friday’s blog post. I also made an AI-generated podcast earlier today that’s a fairly good overview of why the topic is important to registrants.
Below is a quick summary of the submission, as posted to the ICANN comment forum. The 105-page PDF submission is relatively dense and technical, and is intended to be precise for all the (mostly) lawyers reviewing the submissions within ICANN’s processes.
If you agree with our concerns, feel free to submit your own comment endorsing our submission. Or, if you need more time to study the issues, you should ask ICANN to extend the comment period, perhaps until the end of the summer.
Kudos to Ron Jackson of DNJournal for submitting a comment already.
Our position: the draft documents are not aligned with the policy recommendations the ICANN Board adopted in April 2023, and they are not close to it.
We identify 32 numbered changes needed across the three documents — 15 to the UDRP materials, 11 to the URS materials, 6 to the Policy Guidance — plus 11 further points about the process. The number matters less than the direction. Almost without exception, where the adopted recommendations gave a domain name registrant a protection, the drafts remove it, narrow it, or defer it to documents that have not been written; where the adopted recommendations gave intergovernmental organisations something, the drafts deliver it in full and sometimes add to it. A pattern that runs so consistently one way deserves an explanation.
One example, in plain language. The Board adopted a rule that a registrant who takes a dispute to court keeps the domain name while the case is heard. The drafts omit it. A registrant who exercises the very right the Board preserved would lose the name before any judge examines the case — and once a name has passed to an organisation that can assert immunity from national courts, recovering it is, in practice, extremely difficult.
The package is also incomplete. Which arbitration institutions will hear these cases, under what rules, and at what cost are all left blank. The community is being asked to approve a system whose operative content does not yet exist.
We therefore ask ICANN to extend this comment period. It falls across the northern-hemisphere summer; the material is long and technical; and the volume of defects that one outside reviewer found in a few weeks suggests the detailed review that should already have taken place has not. We encourage others — registrars, non-commercial users, and individual registrants — to read the drafts and file comments. Ensuring alignment is ICANN’s obligation rather than the community’s, but on this record it will not happen unless people say so.