[council] To Names Council on WG-C Deadline

[KathrynKL@aol.com]

To the Names Council and ICANN Counsel:
Happy New Year -- I hope the Year 2000 with be a very good year for you and 
your families, and of course ICANN!

In reviewing materials to begin the new year, a few concerns about the DNSO 
website and upcoming deadlines arose.  I would like to raise the following 3 
issues and ask that following changes be made:  

[1] Acronyms:  The DNSO website, even the main homepage, use acronyms that 
are not first defined.  These include GA, WG, and NC.  This makes the website 
very difficult to read and interpret for anyone who is not already familiar 
with the structure and functioning of the DNSO.  I would like to request that 
acronyms be replaced with the full text, and perhaps a hyperlink to a clear, 
concise definition.

[2]  Chair and Alternate Chair to the General Assembly.  Roberto's name and 
Harald's name have been added, but their statements of acceptance have been 
dropped.  Now that they have been elected as Chair and Alternate, many people 
will be looking them up for the first time.  Their statements are valuable, 
and I request that the statements be linked to their names from the DNSO.ORG 
page.

[3]  Comment Deadlines.  For the submission of comments to WG-C, I see a 
fixed date and time for comments.  This time falls midday in the US East 
Coast day and early in the US West Coast day.  It means that the majority of 
a business day is lost to those who want to submit at the deadline (as many 
do).  It also means that the evening is lost to noncommercial organizations, 
small businesses and individuals, many of whom finalize and submit their 
comments after the business day on their personal time.

    I think we set a bad precedent by imposing a fixed time and deadline for 
comments.  In the physical world, such deadlines make sense:  as regulatory 
agencies accept paper filings and have staffs that go home at 5:30pm.  The 
Names Council has no such physical office, and the comments are being filed 
electronically.  Further, deadlines exclude comments, and that is certainly 
not our goal.   

    In this area of commenting, I would like to hold WIPO up as a good 
precedent. WIPO asked that all comments to its domain name proceeding be 
submitted on a certain day -- no time, just a certain day.  This was a fair 
way to handle the issue:  it allowed each country to have its full day and 
night to complete comments.  If one country gets a few more hours in a day, 
there is no harm.  If one country does not get its full hours in a day, I 
believe there is.
    
    So, I formally request that the comments for the WG-C deadline on January 
10 be changed to include a date only, and no time.   This change will make 
the process of comment submission easier for noncommercial groups, 
individuals, and small businesses.

Thank you,
Kathryn Kleiman
NCDNHC