Reminder CCT RT Initial Draft Comments for NCSG
Kathy Kleiman
kathy at KATHYKLEIMAN.COM
Wed May 17 10:33:48 EEST 2017
Milton,
Great additions and critiques of Recommendations 1-15! I've added three
more sections for our review of Recommendations 16 to 50. Please join
us in reviewing and evaluating these recommendations!
Best, Kathy
On 5/17/2017 9:50 AM, Mueller, Milton L wrote:
>
> I have added a bunch of stuff to the document.
>
> *From:*Rafik Dammak [mailto:rafik.dammak at gmail.com]
> *Sent:* Tuesday, May 16, 2017 10:25 PM
> *To:* Mueller, Milton L <milton at gatech.edu>; Kathy Kleiman
> <Kathy at kathykleiman.com>; Ayden Férdeline <icann at ferdeline.com>
> *Cc:* NCSG-DISCUSS at listserv.syr.edu
> *Subject:* Re: [NCSG-Discuss] Reminder CCT RT Initial Draft Comments
> for NCSG
>
> 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
> <mailto: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
> <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
> <mailto: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 <mailto:matthew at INTPOLICY.COM>
>
> To: NCSG-DISCUSS at LISTSERV.SYR.EDU
> <mailto: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/1agDMTd8rDvhDb5mwg6fdfQSyRpQZjtjxmGaqx5NCJG8/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
>
> Image removed by sender.
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> --
>
> Matthew Shears
>
> matthew at intpolicy.com <mailto:matthew at intpolicy.com>
>
> +447712472987 <tel:+44%207712%20472987>
>
> Skype:mshears
>
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