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[wg-b] RE: [wg-c] URGENT: Moratorium on all additions to con

Title: RE: [wg-c] URGENT: Moratorium on all additions to con

Mr. Walsh,

I must agree with Ms. Cade regarding an extension of time for comments to respond to WG-C's Interim Report.  While it is possible that the Office of Advocacy of the U.S. Small Business Administration can respond within the 14-day comment deadline, small business owners and entrepreneurs will face significant difficulties in responding in such a short time period.  I have found in the past that I am unable to solicit input from small businesses within this time period when trying to meet ICANN's deadlines. 

Advocacy believes that a 30-day period for comments is the minimum necessary to solicit comments.  We will be filing comments on the record stating this and asking for a lengthening of the comment period.

We recognize that significant discussion has occurred before the release of the WG-C's Interim Report.  However, to my knowledge, the Interim Report is a the first substantive report of the WG-C that has gathered all of the issues and recommendations into a single report in a coherent form.  The Interim Report is ideally suited for soliciting comment from interested parties that are unable to participate in the day-to-day discussion in WG-C. 

Advocacy does not believe that an extension of the comment deadline would significantly slow the WG-C's efforts.  It would be a one-time occurrence; not a repeated halting for each new member on the WG-C.

Also, I should point out that the U.S. Small Business Administration is a separate agency and not a part of the Department of Commerce.  In fact, the Office of Advocacy is an independent office housed within the SBA.  The Chief Counsel, Jere Glover, was appointed directly by President Clinton so that he  can have the independence necessary to take positions counter to other federal agencies, when necessary to advocate for small businesses.  For further information, please visit our Web site at www.sba.gov/advo.

Eric Menge
Office of Advocacy
U.S. Small Business Administration