My understanding is that the current public comment period is designed for people to comment on what ICANN should do with regard to the Independent Review Panel's (or IRP, as it is abbreviated in many of the ICANN docs) decision that ICANN had violated its own protocols in rejecting ICM's application, and not necessarily to comment on ICM's .XXX concept/proposal as a whole.
I'm working on my comments now, and the approach I'm taking is to endorse "Option 3," the option for ICANN to adopt the findings of the dissent in the IRP decision.
Here's how that option reads in pertinent part in the ICANN document entitled "ICANN Options Following the IRP Declaration on ICM?s .XXX Application."
Quote:
The dissenting opinion of the Panel?s Declaration concluded that ICM never satisfied the sponsorship requirements and criteria for a sponsored TLD, and that the ICANN Board denied ICM?s application for the .XXX sTLD "on the merits in an open and transparent forum." The Board could vote to adopt the dissenting opinion of the Panel?s Declaration on the basis that the Board thinks that the Panel?s majority opinion was wrong and that the Board?s conduct was consistent with ICANN?s Bylaws and Articles of Incorporation.
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So, instead of merely stating that you are a stakeholder and expressing opposition to the .XXX concept, if you are against .XXX being established, I think the thing to do is to restate the IRP's dissenting position that the ICM never satisfied the sponsorship requirements, and then state that the requirement ICM specifically failed to satisfy was demonstrating that they had the support of the "sponsoring community."
At that point in your comments, you can state your case against .XXX (or simply state that you don't want/support it).
That's the approach I'm taking, at least, because I think that unless you invoke the IRP decision specifically, and endorse the notion of adopting the IRP dissenting member's position, ICANN might just skip right over your feedback as irrelevant.
