Reminder CCT RT Initial Draft Comments for NCSG

[Rafik Dammak]

Hi Ayden, Kathy, Milton,

thanks for the comments and suggestion, can you please include them
directly in the google doc?

Best,

Rafik

2017-05-16 7:42 GMT+09:00 Mueller, Milton L <milton at gatech.edu>:

> Kathy
>
> Thanks for calling this out. I have scanned the report and read the
> executive summary and recommendations. This is an odd but very ICANNesque
> report. Look at the basic conclusions the report reached:
>
>
>
> Initial indications are that the New gTLD Program has led to a dramatic
> increase in consumer choice, a modest increase in competition and minimal
> impact on consumer trust.
>
>
>
> Those are the conclusions actually supported by the data. Unfortunately,
> politics set in immediately and the recommendations reflect an attempt by
> the IPR interests – who have completely lost their attempt to show that new
> TLDs were a plague – to win by losing. So the massive number of
> recommendations, several of which call for holding up all new applications
> until dozens of studies and changes are completed, are in effect a fishing
> expedition license that would give the anti-industry crowd another 2 years
> to find some data – any data – that they can use to hold things up even
> longer:
>
>
>
> “Nonetheless, the Review Team believes that there is a substantial need
> for more and better data on both competition and pricing and on the impact
> of safeguards on consumer protection.”
>
>
>
> I agree that the data collection recommendations are excessive and reflect
> the momentum created by a growing bureaucracy. Many have almost nothing to
> do with consumer protection. One could also characterize this as an attempt
> by the CCT RT to prolong its existence. It’s nice being flown around…
>
>
>
> I probably won’t have time to play a big role in comment development but
> would urge you not to go one by one through the 50 recommendations. Rather,
> I would group them into a few simple categories, such as:
>
> A)     Useful
>
> B)      Delaying tactic
>
> C)      Needless bureaucratic expansion that is unjustified by any
> finding in the report
>
>
>
> Finally, I burst out laughing at this one:
>
>
>
> “the CCTRT found that GAC participation in the application and evaluation
> process was largely beneficial and led directly to modifications of
> applications and applicants more successfully navigating the process.”
>
>
>
> Obviously an entirely political finding, for despite repeated references
> to “data-driven analysis” in the report I cannot find any hard data that
> supports this conclusion. I think we should call that out. GAC
> interventions in the application and evaluation process were highly
> disruptive, unfair, inconsistent, persistently deviated from settled GNSO
> policy directions, and resulted in all kinds of shadow regulation. We must
> challenge that finding. At the same time, we should be praising the report
> for basically coming to the right conclusions when they stick to the facts:
> opening up the market for new TLDs increased consumer choice, increased
> competition, and has no discernable negative effect on consumer trust.
>
>
>
> Dr. Milton L Mueller
>
> Professor, School of Public Policy <http://spp.gatech.edu/>
>
> Georgia Institute of Technology
>
> Internet Governance Project
>
> http://internetgovernance.org/
>
>
>
>
>
> *From:* NCSG-Discuss [mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU] *On Behalf Of
> *Kathy Kleiman
> *Sent:* Monday, May 15, 2017 1:20 PM
> *To:* NCSG-DISCUSS at LISTSERV.SYR.EDU
>
> *Subject:* Re: Reminder CCT RT Initial Draft Comments for NCSG
>
>
>
> I agree with Ayden about adding sections that review the recommendations
> one by one. The fact that there are 50 is extraordinary in and of itself.
>
> Some initial thoughts:
> 1)  A large amount of collection of pricing data is requested in Draft
> Recommendations 2-8.  For those who work with pricing issues, what concerns
> are raised by ICANN collecting, publishing and acting on pricing data?
> 2) A number of recommendations direct the GNSO Working Groups to take
> additional interests and concerns into account.  Should a Review Team be
> directing Working Groups and GNSO policy considerations (particularly here
> where the Review Team is putting their fingers on the scale towards the
> interests of Intellectual Property and Business Constituencies?)
> 3) A number of the recommendations are very vague. This gives great power
> and discretion to those who will interpret and implement the
> recommendations. How best to clarify?
> 4) As Ayden points out, Shadow Regulation appears to be an integral part
> of these recommendations -- with a very broad approach to abuse.  How to
> narrow to the type of abuse we generally consider to be within the scope of
> ICANN, e.g,. abuse that impacts the security and stability of the Internet
> (botnets, malware...)
>
> Work ahead!  Please jump in!
> Kathy
>
> On 5/15/2017 10:57 AM, Ayden Férdeline wrote:
>
> Hi all,
>
>
>
> The Google Doc is opening for me. Thanks for the first draft of this,
> Poncelet. I would like to suggest that we structure our comment along the
> 50 (!) recommendations that are in the draft report, if not addressing all
> of them, at least reacting to the most pertinent ones.
>
> From memory, the Canadian International Pharmacy Association expressed
> concern in Copenhagen over similarities between some of the recommendations
> in the CCT RT initial draft and the "Healthy" Domains Initiative. So we
> might want to look out for traces of shadow regulation in the report.
> Thanks.
>
> Best wishes,
>
>
>
> Ayden Férdeline
>
> linkedin.com/in/ferdeline <http://www.linkedin.com/in/ferdeline>
>
>
>
>
>
> -------- Original Message --------
>
> Subject: Re: Reminder CCT RT Initial Draft Comments for NCSG
>
> Local Time: May 15, 2017 2:12 PM
>
> UTC Time: May 15, 2017 1:12 PM
>
> From: matthew at INTPOLICY.COM
>
> To: NCSG-DISCUSS at LISTSERV.SYR.EDU
>
>
>
>
>
> Hi all - thanks Rafik.
>
> Have any third parties - outside of ICANN - done any work on this issue?
> It would be important to see if there has been I think.
>
> Also, I don't seem to be able to access the google.doc  - says I need
> permission.
>
> Thanks.
>
> Matthew
>
>
>
> On 15/05/2017 14:22, Rafik Dammak wrote:
>
> Hi all,
>
>
>
> this is a reminder to review and add your comments on the draft made by
> Poncelet for NCSG on the Competition, Consumer, Consumer Choice review team
> report https://docs.google.com/document/d/1agDMTd8rDvhDb5mwg6fdfQSyRpQZj
> tjxmGaqx5NCJG8/edit
>
> (the public comment is here https://www.icann.org/public-
> comments/cct-rt-draft-report-2017-03-07-en)
>
> the deadline for submission is the 19th May.
>
>
>
> Best,
>
>
>
> Rafik
>
>
>
>
> <http://www.avg.com/email-signature?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=emailclient>
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>
>
>
>
> --
>
> Matthew Shears
>
> matthew at intpolicy.com
>
> +447712472987 <+44%207712%20472987>
>
> Skype:mshears
>
>
>
>
>
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