[PC-NCSG] RAA public comment -- quick proposal

[Wendy Seltzer]

I found Joy's text, and will borrow liberally for a personal statement.
Do we have consensus on these for an NCSG position, or should we submit
that shortly after, in the "reply" period?


NCSG DRAFT POINTS:



?    Violates multi-stakeholder, bottom-up principles ? no community
consultation on the proposed amendments: bilateral contract
negotiations shouldn't set policy in a multi-stakeholder environment
?    Abrogates the picket fence
?    Not evidence based and therefore irrational and no legal basis: no
evidence has been provided of a problem necessitating this solution;
no persuasive rationale has been presented and in any event, any such
evidence/rationale must be subject to community input
?    Registrants rights and responsibilities bogus document and should
not have been tabled without input from community and especially
across community constituencies
?    Privacy/proxy [I believe Wendy had a point about this, but I can?t
recall it exactly]
?    The process for these negotiations and the introduction of powers of
unilateral decision-making are under-mining our advocacy for the ICANN
model in other multi-stakeholder fora
?    At the GNSO Council meeting, ICANN staff advised the rationale was
?this is the process for negotiation? ? this is fundamentally the
wrong approach to the RAA as this is public, not private, policy making
?    We support the Registrars and Registries in their opposition to
these proposals.


On 03/28/2013 12:41 PM, Robin Gross wrote:
> I agree that we really need to get a statement in on this issue asap.  I
> thought Joy had sent around a draft stmt a couple weeks ago (or a few
> points to go into a stmt).
> 
> Or I have I completely lost my marbles?
> 
> Thanks,
> Robin
> 
> On Mar 28, 2013, at 9:37 AM, Wendy Seltzer wrote:
> 
>> We didn't get a draft statement on the RAA circulated. What would people
>> think of sending a quick endorsement of the Registrars' statement?
>>
>> Namely,
>> "NCSG supports the registrars in their procedural and substantive
>> concerns with ICANN's negotiation position:
>> http://forum.icann.org/lists/comments-proposed-raa-07mar13/msg00000.html
>> "
>>
>> I'll still try to draft something more substantial to send personally,
>> but not sure given timing.
>>
>> --Wendy
>>
>> -- 
>> Wendy Seltzer -- wendy at seltzer.org +1 617.863.0613
>> Policy Counsel, World Wide Web Consortium (W3C)
>> Fellow, Berkman Center for Internet & Society at Harvard University
>> Visiting Fellow, Yale Law School Information Society Project
>> http://wendy.seltzer.org/
>> https://www.chillingeffects.org/
>> https://www.torproject.org/
>> http://www.freedom-to-tinker.com/
>>
>> _______________________________________________
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>> PC-NCSG at ipjustice.org
>> http://mailman.ipjustice.org/listinfo/pc-ncsg
>>
> 
> 
> 
> 
> IP JUSTICE
> Robin Gross, Executive Director
> 1192 Haight Street, San Francisco, CA  94117  USA
> p: +1-415-553-6261    f: +1-415-462-6451
> w: http://www.ipjustice.org     e: robin at ipjustice.org
> 
> 
> 
> 


-- 
Wendy Seltzer -- wendy at seltzer.org +1 617.863.0613
Policy Counsel, World Wide Web Consortium (W3C)
Fellow, Berkman Center for Internet & Society at Harvard University
Visiting Fellow, Yale Law School Information Society Project
http://wendy.seltzer.org/
https://www.chillingeffects.org/
https://www.torproject.org/
http://www.freedom-to-tinker.com/