[Comment-Geo] Inadequate Time To Comment on Geographic Diversity

["Tom Lowenhaupt" <tjpl@ix.netcom.com>]

Section 3 of the ICANN By Laws makes it clear that ICANN is to post proposed
rules on its web site that "substantially affect the operation of the
Internet" and then to "provide a reasonable opportunity for parties to
comment on the adoption of the proposed policies, to see the comments of
others, and to reply to those comments". (see detail of Section 3 below.)

I guess there is such a thing as "Internet Time", and by that standard this
notification is more than adequate. However, the By Laws call for providing
a "Reasonable opportunity" to comment and participate. This has not been
provided in this instance.

I suggest taking comments at the Berlin meeting and considering the
resolution in light of those comments at the next appropriate meeting.

Sincerely,

Tom Lowenhaupt
------------------------
>From ICANN By Laws

Section 3. NOTICE AND COMMENT PROVISIONS

(a) The Board shall post on the Web Site (i) periodically a calendar of
scheduled meetings for the upcoming year, and (ii) in advance of each Board
meeting, a notice of the fact and time that such meeting will be held and,
to the extent known, an agenda for the meeting. If reasonably practicable,
the Board shall post notices of special meetings of the Board at least
fourteen (14) days prior to the meetings.

(b) With respect to any policies that are being considered for adoption that
substantially affect the operation of the Internet or third parties,
including the imposition of any fees or charges, the Board will:

(i) provide public notice on the Web Site explaining what policies are being
considered for adoption and why;

(ii) provide a reasonable opportunity for parties to comment on the adoption
of the proposed policies, to see the comments of others, and to reply to
those comments; and

(iii) hold a public forum at which the proposed policy would be discussed.

(c) After voting on any policy subject to Section 3(b) of this Article, the
Board will publish in the meeting minutes the reasons for any action taken,
the vote of each Director voting on the action, and the separate statement
of any Director desiring publication of such a statement.

(d) As appropriate, the Corporation will facilitate the translation of final
published documents into various appropriate languages.