[process2-comments] RFC-1

 Name: Alan Davidson Organization: Center for Democracy & Technology Position: Staff Counsel September 15, 2000 Office of Legal and Organization Affairs World Intellectual Property Organization 34, chemin des Colombettes P.O. Box 18 1211 Geneva 20 SWITZERLAND Dear Sir or Madam: The Center for Democracy and Technology is pleased to participate in the first Request for Comments on WIPO's Second Internet Domain Name Process. However, we are concerned that the current WIPO proposal will not adequately represent and include the interests of consumers and Internet users in WIPO's important deliberations. WIPO's online activities significantly affect the interests of the Internet public, particularly concerning freedom of expression online. WIPO's earlier work in this and its record thus far as an arbiter of domain name disputes has led to heated debate about users' rights on the Internet. In light of that debate, WIPO should redouble its efforts to demonstrate a commitment to including the interests of the Internet public in its deliberations. In the First Process, WIPO assembled a group of experts from the community to assist the Process throughout its development. While that group itself was not without controversy, the current process does not even include this initial step towards broad outreach. We urge WIPO to solicit the participation of outside experts in the Second Process, particularly those who can represent the interests of consumers, domain name holders, and Internet users, and to make frequent and determined use of them in all stages of the Process. We are also concerned that the proposed regional consultation schedule is not substantially global in character. At this time, WIPO has not scheduled consultations in several important regions, including Western Europe, North America, Australia, and the Far East. We hope that WIPO will revise its schedule to include consultations with individuals and organizations in these areas, so as to ensure that its Process is as accessible as possible to all interests. Thank you for the opportunity to comment on this important phase of development for WIPO and the Second Process. Sincerely, Alan Davidson Staff Counsel Center for Democracy & Technology