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[Comment-Irac] The IRP

Under U. S. practice, and no doubt under similar practices elsewhere,
"independent review" occurs by way of an entity that is not only
"independent" of the organization being reviewed but indeed has its
own source of power.  Examples obvious to Americans are Congressional
Oversight Committees that are supposed to track the operations of one
or the other executive branch function, and similarly the courts that, in
a certain sense, "oversee" both the legislative and executive branches.
The U. S. does utilize the "Inspector General" mode, or similarly the
General Accounting Office mode, wherein an entity within the branch 
oversees the functions of other entities in that same branch, but the 
authority of Inspectors General and the like have long been recognized,
and the reports therefrom are taken seriously within other branches.
There is nothing in this proposal that would establish an equivalent
level of authority in the IRP, and it is doubtful that any IRP can be
effective without such authority.  I concur with another comment in
which it is stated that if California Corporate law does not allow for
such "external" control, then a more liberal venue for ICANN should
be sought out.

William S. Lovell