[governance] IANA transition - BR Gov comments on the CCWG-Accountability Draft Proposal

Michael Froomkin - U.Miami School of Law froomkin at law.miami.edu
Thu Jun 11 10:16:58 EDT 2015


I am afraid that the door for any recourse via NITA is basically shut at 
present.  I have three relevant articles that trace the developments.

Wrong Turn in Cyberspace: Using ICANN to Route Around the APA and the 
Constitution, 50 DUKE L.J. 17 (2000), 
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=252523

Form and Substance in Cyberspace, 6 J. SMALL & EMERGING BUS. L. 93 (2002), 
http://www.law.miami.edu/%7Efroomkin/articles/formandsubstance.pdf

Almost Free: An Analysis of ICANN’s ‘Affirmation of Commitments’, 9 J. 
Telecom. & High Tech. Law 187 (2011), http://ssrn.com/abstract=1744086

If you are in a rush, just read the last one.


On Wed, 10 Jun 2015, Seth Johnson wrote:

> On Wed, Jun 10, 2015 at 7:11 PM, Michael Froomkin - U.Miami School of
> Law <froomkin at law.miami.edu> wrote:
>> Just to head off a possible and no doubt unintentional misunderstanding:
>>
>> Non-US persons have recourse to US courts for many things, including
>> contractual rights.  Non-US persons located outside the US do not, in the
>> main, have the right to make constitutional claims or defenses against the
>> US government.  But since ICANN, or New New Co., is not part of the US
>> government, this is not relevant.
>>
>> If a corporation is located in a US state, then it can be sued there by
>> **anyone*** from ***anywhere*** so long as they are in fact alleging facts
>> showing they were wronged by it.  In other words, the issue is what (mainly
>> private law) rights one might have to assert, not whether the court will
>> hear you due to your citizenship or domicile or even (if represented by
>> counsel) location.
>
>
> Right.  I am speaking specifically about fundamental rights claims
> against the government, which is the key thing I emphasize we need to
> understand.  I am also not talking about the issues related to the
> corporate form.  I believe I am correct that there would be a basis
> for recourse against the US government via the NTIA connection, though
> I'm unsure about whether that basis applies to ICANN in particular in
> the present relationship.  Removing that connection in the IANA
> functions would remove even that basis for a fundamental rights claim
> as it's then private.  I'm not too sure how strong the basis for the
> claim via NTIA would be, but if it's a question of fundamental rights
> it would be heightened scrutiny inasmuch as the activities in question
> can be attributed to the US government.  And the US doesn't muck
> around with the IANA or any other Internet-related stewardship area,
> as it's all so close to areas of free speech, association, press (and
> searches and seizures) (which is central to my message here)  --
> except through the international arena, where there are ways to get in
> there (and which is really a big part of what's going on with the
> whole transition, whether IANA or "Internet governance" in general).
>
> My emphasis in this thread is not on the corporate form, or private
> issues in general.  You and I are talking about different angles, but
> I am also concerned about the corporate angle; I just emphasize that
> on a kind of first principles basis (and things that I think need to
> be understood in general as first principles), the way to examine a
> transition to the international arena should be looked at in this
> light first.
>
> One can certainly go to court in the US on all sorts of diversity
> jurisdiction bases -- other than fundamental rights claims, which as
> you say have to be of a citizen against their government.
>
> I have plenty to say about the corporate form, but it's a very
> different story.  That tends to be what people talk about first.
> People want to talk that way rather than sound like they're
> questioning "good governance" in this area (which I'm not; I might
> sound  anti-government or like a latter-day radical libertarian here,
> but I'm really just describing the relationship between people and
> their fundamental rights and the government).  However, I think we get
> someplace clearer, sooner, in terms of properly characterizing the
> international arena, with regard to fundamental rights.
>
> I really want to go way back on the corporate form and the whole US
> legacy of federal common law and forum shopping.  But we really messed
> that domain up royally, from way back.  Then again, we didn't know
> enough to consider it as an issue for the constitutional moment, which
> I think it really should have been if we'd known enough back then.
>
>
> Seth
>
>
>
>> On Wed, 10 Jun 2015, Seth Johnson wrote:
>>
>>> On Wed, Jun 10, 2015 at 2:51 PM, Mawaki Chango <kichango at gmail.com> wrote:
>>>>
>>>> Simple and maybe trivial question, again (since my previous one about
>>>> delegation hasn't found a taker.)
>>>>
>>>> Scenario 1*: I am a citizen of Togo, quite a small country sitting on the
>>>> belly of Africa to the west (you may check our macro economic indicators
>>>> in
>>>> the CIA Facebook or from the World Bank online sources.) I am a domain
>>>> name
>>>> registrant. In year 2018 ICANN makes a decision, later upheld by the
>>>> conflict resolution mechanism in place, but which I think violates my
>>>> fundamental rights as I understand them by any international standards. I
>>>> am
>>>> even pretty convinced that I might win the case in a US court based on
>>>> the
>>>> documentation available /jurisprudence in that country. Problem is, I
>>>> have
>>>> no access to the institutional resources that would allow me to use the
>>>> US
>>>> judicial system as a plaintiff, much less the financial resources it
>>>> would
>>>> take to get a lawyer to represent my interests.
>>>>
>>>> Is that -- the need for everybody to be equal before the law, in
>>>> practice,
>>>> and have their rights equally secured, -- in your view, a problem worthy
>>>> of
>>>> our attention? If so how can we address it.
>>>
>>>
>>>
>>> It is.  But no, you would not have recourse to US courts.  The problem
>>> for the international arena is that nobody has that "trump card"
>>> recourse that keeps governments in check *other than* those who have a
>>> claim that their own government is doing or allowing things to happen
>>> that violate their own fundamental rights as a citizen.  The kind of
>>> rights you get internationally are really almost what we call
>>> statutory rights -- the problem being that the "legislature" can
>>> always rewrite those kinds of rights.  Or, since in fact going and
>>> revising a treaty provision regarding rights poses some political
>>> difficulty, what you'll see more often is that the rights expressed in
>>> treaties have no more weight against things like "national interests"
>>> or "national security" or the "war on" x, y, and z -- than a
>>> "balancing standard."  Governments can well do whatever they say is
>>> necessary (like vacuum up all communications for surveillance, or for,
>>> hey, regular spying) for their national interests and they essentially
>>> just "bear in mind" whatever rights are expressed in treaties.  And no
>>> judge in an ostensible international tribunal can really simply cancel
>>> a treaty the way they can an unconstitutional law in a national
>>> context (without a clear founding act prior to the government, where
>>> the people(s) claim their priority and authorize government(s) to
>>> proceed only under certain limits).  Treaties are agreements among
>>> governments, so what the governments "meant" is what you have to
>>> deliberate over in interpreting the treaties -- not over whether the
>>> people have rights regardless of the governments' intention in the
>>> treaty.  A judge would at best weigh treaty elements and try to
>>> articulate how to settle all parts without saying any part is
>>> "unconstitutional."  The problem is how to get the closest you can to
>>> that kind of a "trump card" standing for fundamental rights.
>>>
>>> An ostensible "constitution" among governments (like the ITU's) has
>>> the same problem.  In general, the way the real claim of priority of
>>> the people and their rights happens is when the people self-evidently
>>> act to fill in the gap when a government is rendered illegitimate (or
>>> overthrown): acting independent of the pre-established government to
>>> select delegates to their own constitutional convention, draft a
>>> constitution, and then ratify it -- they thereby set a definitive
>>> historical register of the people setting limits that the government
>>> must thenceforth operate within to be legitimate.  This is called the
>>> "constituent power."  Historians point at Massachusetts as the first
>>> US colony/state to exercise the consttuent power that way -- when the
>>> towns rejected the state constitution the state legislature had
>>> written for them and insisted on having their own constitutional
>>> process.  It was done by similar principles for the US federal
>>> constitution.  That's how you get a fundamental right "trump card."
>>>
>>> If you have that, and it's exercised a few times well or for a while,
>>> then you have a situation where goverments are in check -- they don't
>>> overreach too obviously, or they test the boundaries but they get
>>> trumped by a judiciary that's rooted that way.
>>>
>>> You posed the question of equal rights before the law, in the
>>> international context.  I certainly do not advocate a global
>>> revolution where all the people(s) seize a moment to stop their
>>> governments and tell them how they may all proceed.
>>>
>>> What I have tended to suggest is approaches that can be interim
>>> measures that tend towards the principles that we want to have in
>>> play, but which we can't yet quite have in play.
>>>
>>> One approach that seems like a way towards that kind of conception
>>> might be: Imagine a bicameral "House of Rights" or more narrowly an
>>> "International Internet Communications Rights Forum."  It doesn't need
>>> to say "Rights," though that's the point, so maybe call it an
>>> "Internet Stewards House."  This is modeled like a legislature, with a
>>> house to represent countries equally, and another house to represent
>>> populations proportionally -- except it's not empowered to write law
>>> (or treaties), but rather to play the role of voting to *veto* acts of
>>> other (or some one or few other) intergovernmental bodies that
>>> actually do start enacting binding "legislation."  You might be able
>>> to get freedom-loving countries to endorse constructing something like
>>> that, and while it's not as solid as court rulings that keep all
>>> lawlike activities in check more definitively, it would be a solid
>>> register of the priority of rights.
>>>
>>> There are a lot of holes in that, but I think it conveys something of
>>> the kind of concerns and how they might be approached that we should
>>> really have in mind rather than blindly handing things off to the
>>> international arena (which is really *always* "intergovernmental" --
>>> governments are the entities that act there).
>>>
>>> So, that's a sort of answer, stab at describing things properly and
>>> with some sort of practical conception.  I don't press specific
>>> solutions though, just describe notions that I think can give people a
>>> better understanding of the real nature of the difficulties and
>>> problems involved.
>>>
>>> Ponder that; you'll think of plenty of problems with it.  But the
>>> important thing is this is a far more real characterization of the
>>> situation.  And I describe an idea like this solely to set a proper
>>> stage for talking about things with a better sense of what's going on.
>>> Take it as a brainstorm.  But also take it as a reality check and a
>>> call and challenge to try to define and understand the situation
>>> properly and well.
>>>
>>> (The above line of exposition talks mostly about governmental-related
>>> issues.  The issues brought by the corporate form are a whole other
>>> area that also needs fuller appreciation.  And really, we most want
>>> not to be so governmental [even those of us stressing the validity of
>>> the role of government]; we want to just build our Internet and let
>>> that be mostly a discussion of how to solve problems in a technical
>>> way and one where our rights aren't on the line.)
>>>
>>> See what you think of that.
>>>
>>>
>>> Seth
>>>
>>>> Thanks
>>>>
>>>> (*) I only have one scenario for now but I'm numbering #1 just in case
>>>> others come up later in the discussion.
>>>>
>>>> /Brought to you by Mawaki's droid agent
>>>>
>>>> On Jun 10, 2015 3:57 PM, "Seth Johnson" <seth.p.johnson at gmail.com> wrote:
>>>>>
>>>>>
>>>>> I believe the most important focus is on the question of how to
>>>>> install effective fundamental liberties limits in the context of an
>>>>> international political forum.  That's how you can hope to maintain
>>>>> the type of stewardship context we want associated with a medium of
>>>>> communication.  The presence of recourse of that sort -- related to
>>>>> being based in a national context -- is one of the main reasons why
>>>>> ICANN has not gone further off the rails.  Same as for government in
>>>>> general in such a national context: we don't get the government
>>>>> meddling specifically because the relationship to the national context
>>>>> (via the bare presence of NTIA) means the people (at least of the US)
>>>>> have recourse against it if it does.
>>>>>
>>>>> Keep in mind that one of the chief reasons why Obama (and his
>>>>> predecessor) have gone off the rails with surveillance and other
>>>>> fundamental rights violations is because they have the notion that the
>>>>> international arena provides means to act that way without the
>>>>> recourse we have against it domestically.  There's still the problem
>>>>> of laundering the surveillance by having private corporations (whether
>>>>> telco or app) do it on the government's behalf.  But we see an effort
>>>>> at long last to try to "legitimize" what they're doing that way at
>>>>> least (more apparent effort to not violate citizens in the domestic
>>>>> sphere), because we finally got standing in the courts, and
>>>>> documentation that was taken seriously via Snowden.  Still just
>>>>> domestic, so that doesn't answer general concerns, but this should
>>>>> highlight the nature of the problem.  You don't actually have
>>>>> fundamental rights in the international arena, no matter how many
>>>>> human rights treaties you pass.  That's not what secures rights
>>>>> against acts of governments.
>>>>>
>>>>> Note that this is stuff the UN has been utterly clueless about for
>>>>> years and years and years, along with many followers-on.  And I think
>>>>> in general the parties who have been acting in the international arena
>>>>> like it that way.  We, the people(s), are really the ones to bring it
>>>>> into the discourse in a real way, now that we are here in proceedings
>>>>> that deign to appear to engage us substantively in international
>>>>> policy.
>>>>>
>>>>>
>>>>> Seth
>>>>>
>>>>> On Wed, Jun 10, 2015 at 10:36 AM, Michael Froomkin - U.Miami School of
>>>>> Law <froomkin at law.miami.edu> wrote:
>>>>>>
>>>>>> On Wed, 10 Jun 2015, Chris Prince Udochukwu Njoku wrote:
>>>>>>
>>>>>>>
>>>>>>> Parminder is emphasizing a true point. An organization which
>>>>>>> represents
>>>>>>> the
>>>>>>> interests of many nations, though located in one nation (as it must
>>>>>>> be)
>>>>>>> must
>>>>>>> not be subjected to laws that ought to be (and are) for national
>>>>>>
>>>>>>
>>>>>>
>>>>>> It is, I think, possible to act as a trustee of international interests
>>>>>> while still having accountability rooted in national law.  It may not
>>>>>> be
>>>>>> possible to accommodate the desires of governments to, in effect, serve
>>>>>> directly on the governing body given the view of e.g. the Brazilian
>>>>>> government that this is unacceptable subordination to another state,
>>>>>> but
>>>>>> some may see that as a feature rather than a bug.
>>>>>>
>>>>>>
>>>>>>> organizations. This should be the definition of international
>>>>>>> jurisdiction
>>>>>>> here. If the host nation's laws don't actually accommodate the
>>>>>>> multinational
>>>>>>> stakeholding nature of the organization, it's a ripe clue to the need
>>>>>>> for
>>>>>>> relocation to a place that is more friendly to the organization's
>>>>>>> operations.
>>>>>>>
>>>>>>
>>>>>> The above contains a term that (to a lawyer) has multiple possible
>>>>>> meanings.
>>>>>> The traditional way to " accommodate the multinational ... nature" of
>>>>>> an
>>>>>> organization is to incorporate it in Switzerland, and have no effective
>>>>>> supervision.  FIFA.  IOC.  No thanks.
>>>>>>
>>>>>> So I would ask, what is the threat model here?  What is a (mildly
>>>>>> realistic)
>>>>>> example of a scenario in which one fears the entity will do something
>>>>>> legitimate and a national court (of the US, Canada, the nation of your
>>>>>> choice) would have an appreciable chance of blocking it?  I would note,
>>>>>> for
>>>>>> example, that the only time I can think of that a US court overruled
>>>>>> ICANN
>>>>>> was when it froze out one of its own directors because the staff
>>>>>> disagreed
>>>>>> with his views.  That violated California law empowering directors not
>>>>>> to
>>>>>> mention any sense of natural justice.  The result was not only just, it
>>>>>> was
>>>>>> necessary.  And it is Exhibit A as to why we cannot simply trust in
>>>>>> ICANN,
>>>>>> or New New Co's, good faith.
>>>>>>
>>>>>> In other words, I submit that national court supervision in an
>>>>>> appropriate
>>>>>> and democratic jurisdiction is far, far more likely to produce good
>>>>>> outcomes
>>>>>> than bad ones, while the removal of this valuable check is almost
>>>>>> certain to
>>>>>> lead to difficulties.  What is more, those difficulties will not be
>>>>>> prevented by having the body be "international" for any currently known
>>>>>> meaning of the term.
>>>>>>
>>>>>> Contrary to other messages in this thread, I do not believe that there
>>>>>> is
>>>>>> much in the way of effective monitoring of many multi-national treaty
>>>>>> bodies
>>>>>> other than by action of the member states.  No one else has much real
>>>>>> leverage over WIPO, GATT, you name it.  NGOs have some moral and
>>>>>> intellectual suasion, but some of their clout also comes from the fact
>>>>>> that
>>>>>> it influences or might influence the members.
>>>>>>
>>>>>> I prefer to attempt to engineer a much surer means of dealing with
>>>>>> major
>>>>>> and
>>>>>> substantially foreseeable problems.
>>>>>>
>>>>>>
>>>>>>> On Jun 10, 2015 11:27 AM, "parminder" <parminder at itforchange.net>
>>>>>>> wrote:
>>>>>>>
>>>>>>>
>>>>>>>       On Tuesday 09 June 2015 09:09 PM, Michael Froomkin - U.Miami
>>>>>>>       School of
>>>>>>>       Law wrote:
>>>>>>>     > On Tue, 9 Jun 2015, parminder wrote:
>>>>>>>     >
>>>>>>>     >> Are you saying that it is not possible for ICANN to undertake
>>>>>>>       the
>>>>>>>     >> functions that it needs to
>>>>>>>     >> undertake while being an international institution
>>>>>>>       incorporated under
>>>>>>>     >> international law, and free
>>>>>>>     >> from any countries jurisdiction in terms of its basic
>>>>>>>       governance
>>>>>>>     >> functions? I just want to be clear.
>>>>>>>     >
>>>>>>>     > I don't know what an "an international institution
>>>>>>>       incorporated under
>>>>>>>     > international law" is except bodies like FIFA (under Swiss
>>>>>>>       law), or UN
>>>>>>>     > bodies, or sui generis treaty bodies.  It is certainly
>>>>>>>       *possible* for
>>>>>>>     > ICANN to have any of those statuses and to "function"; as far
>>>>>>>       as I can
>>>>>>>     > tell, however, it's just not possible to build in meaningful
>>>>>>>     > accountability in those structures.
>>>>>>>
>>>>>>>       There are of course problems and issues everywhere, but it can
>>>>>>>       hardly be
>>>>>>>       said that UN and/or treaty bodies work without meaningful
>>>>>>>       accountability. Further, any new international treaty/ law
>>>>>>>       establishing
>>>>>>>       a new body - an really international ICANN for instance - can
>>>>>>>       write all
>>>>>>>       the accountability method it or we want to have written in it.
>>>>>>>     >
>>>>>>>     > There is no general international law of incorporation of
>>>>>>>       which I am
>>>>>>>     > aware.  Corporate (formation) law is all national law.  That
>>>>>>>       is the
>>>>>>>     > reality that must be confronted.  There is no place I can go
>>>>>>>       to get an
>>>>>>>     > international corporate charter, and good thing too - why
>>>>>>>       should I be
>>>>>>>     > able to exempt myself from national law?
>>>>>>>
>>>>>>>       This hits a fundamental issue - I see ICANN, in its ideal form,
>>>>>>>       as a
>>>>>>>       governance body, since it does governance functions, and not as
>>>>>>>       a
>>>>>>>       private corporation. So we need a new international treaty
>>>>>>>       sanctifying
>>>>>>>       ICANN as a global governance body - with its basic forms largely
>>>>>>>       unchanged, with new accountability means (including judicial
>>>>>>>       accountability) and not ways to be able incorporate a private
>>>>>>>       kind of an
>>>>>>>       entity outside national laws, which is admittedly both very
>>>>>>>       difficult,
>>>>>>>       and rather undesirable.
>>>>>>>
>>>>>>>       parminder
>>>>>>>
>>>>>>>     >
>>>>>>>     >>
>>>>>>>     >> If so, that would be an interesting assertion. Now, I am sure
>>>>>>>       this is
>>>>>>>     >> not true. However, I am not an
>>>>>>>     >> international legal expert and not able to right now build
>>>>>>>       and
>>>>>>>     >> present the whole scenario for you on
>>>>>>>     >> how it can be done. I am sure there are a number of
>>>>>>>       international
>>>>>>>     >> organisations that do different
>>>>>>>     >> kind of complex activities and have found ways to do it under
>>>>>>>     >> international law and jurisdiction.
>>>>>>>     >
>>>>>>>     > But those are in the main treaty bodies.
>>>>>>>     >
>>>>>>>     >> And if some new directions and evolutions are needed that can
>>>>>>>       also be
>>>>>>>     >> worked out (please see my last
>>>>>>>     >> email on this count).
>>>>>>>     >>
>>>>>>>     >
>>>>>>>     > Here we just disagree. I see the task as monsterously hard,
>>>>>>>       the work
>>>>>>>     > of a decade or more.
>>>>>>>     >
>>>>>>>     >> BTW it is a sad statement on the geo political economy of
>>>>>>>       knowledge
>>>>>>>     >> production in this area that
>>>>>>>     >> there is not one full fledged scenario developed by anyone on
>>>>>>>       how
>>>>>>>     >> ICANN can undertakes its
>>>>>>>     >> activities under international law/ jurisdiction - which I am
>>>>>>>       pretty
>>>>>>>     >> sure it can. Many parties,
>>>>>>>     >> including governments have called for it, and yes I agree
>>>>>>>       someone
>>>>>>>     >> should come up with a full
>>>>>>>     >> politico-legal and institutional description of how it can
>>>>>>>       and should
>>>>>>>     >> be done - with all the details
>>>>>>>     >> in place. And that is the sad part of it, of how things stand
>>>>>>>       at the
>>>>>>>     >> global level, had now lopsided
>>>>>>>     >> is resource distribution, all kinds of resources.
>>>>>>>     >>
>>>>>>>     >
>>>>>>>     > Alas.
>>>>>>>     >
>>>>>>>     >> Not to shy away from responsibility - I am happy to
>>>>>>>       collaborate with
>>>>>>>     >> anyone if someone can out time
>>>>>>>     >> into it.
>>>>>>>     >>
>>>>>>>     >> And no, it cannot be solved by any other country
>>>>>>>       jurisdiction. Apart
>>>>>>>     >> from it being still being wrong
>>>>>>>     >> in principle, how would US accept that another jurisdiction
>>>>>>>       is better
>>>>>>>     >> than its own and accede to
>>>>>>>     >> such a change. Accepting the patently justified fact that an
>>>>>>>     >> international infrastructure should be
>>>>>>>     >> governed internationally, on the other hand, is much easier .
>>>>>>>     >>
>>>>>>>     >
>>>>>>>     > I would not dismiss this so quickly.  I take a substantial
>>>>>>>       fraction of
>>>>>>>     > the opposition to US residual control (for that is all we are
>>>>>>>       talking
>>>>>>>     > about) to be tied to the US's status as defacto hegemon.
>>>>>>>       Moving ICANN
>>>>>>>     > to another state with a strong human rights record would
>>>>>>>       answer that
>>>>>>>     > part of the critique.
>>>>>>>     >
>>>>>>>     > In my view, a bespoke international structure is actually much
>>>>>>>       harder
>>>>>>>     > -- it would need to be invented almost from scratch.  And it
>>>>>>>       is bound
>>>>>>>     > to be flawed; national rules are the result of at least
>>>>>>>       decades if not
>>>>>>>     > more of trial and error.
>>>>>>>     >
>>>>>>>     >> parminder
>>>>>>>     >>
>>>>>>>     >> On Tuesday 09 June 2015 07:31 PM, Michael Froomkin - U.Miami
>>>>>>>       School
>>>>>>>     >> of Law wrote:
>>>>>>>     >>       I don't know what it means to say that ICANN should be
>>>>>>>       subject
>>>>>>>     >> to "international
>>>>>>>     >>       jurisdiction and law".  For the relevant issues, that
>>>>>>>       sounds
>>>>>>>     >> like a pretty empty set.
>>>>>>>     >>
>>>>>>>     >>       As regards most of the sort of things one might expect
>>>>>>>       to worry
>>>>>>>     >> about - e.g. fidelity to
>>>>>>>     >>       articles of incorporation - international law is
>>>>>>>       basically
>>>>>>>     >> silent.  And there is no
>>>>>>>     >>       relevant jurisdiction either.  So I remain stuck in the
>>>>>>>     >> position that there must be a
>>>>>>>     >>       state anchor whose courts are given the job.  It does
>>>>>>>       not of
>>>>>>>     >> course need to be the US,
>>>>>>>     >>       although I would note that the US courts are by
>>>>>>>       international
>>>>>>>     >> standards not shy and
>>>>>>>     >>       actually fairly good at this sort of thing.
>>>>>>>     >>
>>>>>>>     >>       I do think, however, that it should NOT be Switzerland,
>>>>>>>       as its
>>>>>>>     >> courts are historically
>>>>>>>     >>       over-deferential to international bodies - perhaps as
>>>>>>>       part of
>>>>>>>     >> state policy to be an
>>>>>>>     >>       attractive location for those high-spending
>>>>>>>       international
>>>>>>>     >> meetings.
>>>>>>>     >>
>>>>>>>     >>       I'd be real happy with Canada, though.
>>>>>>>     >>
>>>>>>>     >>       On Tue, 9 Jun 2015, parminder wrote:
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>             On Tuesday 09 June 2015 06:26 PM, Michael
>>>>>>>       Froomkin -
>>>>>>>     >> U.Miami School of Law
>>>>>>>     >>             wrote:
>>>>>>>     >>
>>>>>>>     >>                   I think that bodies which do not need to
>>>>>>>       fear
>>>>>>>     >> supervision by
>>>>>>>     >>             legitimate courts end up
>>>>>>>     >>                   like FIFA. FIFA had a legal status in
>>>>>>>       Switzerland
>>>>>>>     >> that basically
>>>>>>>     >>             insulated it the way
>>>>>>>     >>                   that the Brazilian document seems to
>>>>>>>       suggest would
>>>>>>>     >> be what they want
>>>>>>>     >>             for ICANN.  (It's
>>>>>>>     >>                   also the legal status ICANN has at times
>>>>>>>       suggested
>>>>>>>     >> it would like.)
>>>>>>>     >>
>>>>>>>     >>                   The lesson of history seems unusually clear
>>>>>>>       here.
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>             Agree that ICANN cannot be left jurisdictionally
>>>>>>>     >> un-supervised - that may be
>>>>>>>     >>             even more dangerous
>>>>>>>     >>             than the present situation. However, the right
>>>>>>>     >> supervision or oversight is
>>>>>>>     >>             of international
>>>>>>>     >>             jurisdiction and law, not that of the US . This
>>>>>>>       is what
>>>>>>>     >> Brazil has to make
>>>>>>>     >>             upfront as the
>>>>>>>     >>             implication of what it is really seeking, and its
>>>>>>>       shyness
>>>>>>>     >> and reticence to
>>>>>>>     >>             say so is what I noted as
>>>>>>>     >>             surprising in an earlier email in this thread.
>>>>>>>       Not
>>>>>>>     >> putting out clearly what
>>>>>>>     >>             exactly it wants would
>>>>>>>     >>             lead to misconceptions about its position, which
>>>>>>>       IMHO can
>>>>>>>     >> be seen from how
>>>>>>>     >>             Michael reads it.  I am
>>>>>>>     >>             sure this is not how Brazil meant it - to free
>>>>>>>       ICANN from
>>>>>>>     >> all kinds of
>>>>>>>     >>             jurisdictional oversight
>>>>>>>     >>             whatsoever - but then Brazil needs to say clearly
>>>>>>>       what is
>>>>>>>     >> it that it wants,
>>>>>>>     >>             and how can it can
>>>>>>>     >>             obtained. Brazil, please come out of your
>>>>>>>       NetMundial
>>>>>>>     >> hangover and take
>>>>>>>     >>             political responsibility for
>>>>>>>     >>             what you say and seek!
>>>>>>>     >>
>>>>>>>     >>             parminder
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>                   On Tue, 9 Jun 2015, Mawaki Chango wrote:
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>                         It's good to see a law scholar
>>>>>>>       involved in
>>>>>>>     >> this discussion. I'll
>>>>>>>     >>             leave it to
>>>>>>>     >>                         the Brazilian party to
>>>>>>>     >>                         ultimate tell whether your reading is
>>>>>>>       correct
>>>>>>>     >> or not. In the
>>>>>>>     >>             meantime I'd
>>>>>>>     >>                         volunteer the following
>>>>>>>     >>                         comments.
>>>>>>>     >>
>>>>>>>     >>                         On Jun 8, 2015 10:46 PM, "Michael
>>>>>>>       Froomkin -
>>>>>>>     >> U.Miami School of
>>>>>>>     >>             Law"
>>>>>>>     >>                         <froomkin at law.miami.edu> wrote:
>>>>>>>     >>                       >
>>>>>>>     >>                       > Perhaps I'm misreading something,
>>>>>>>       but I
>>>>>>>     >> read this document to
>>>>>>>     >>             make the
>>>>>>>     >>                         following assertions:
>>>>>>>     >>                       >
>>>>>>>     >>                       > 1. All restrictions on ICANN's
>>>>>>>       location
>>>>>>>     >> must be removed.
>>>>>>>     >>                       >
>>>>>>>     >>
>>>>>>>     >>                         And the question reopened for
>>>>>>>       deliberation by
>>>>>>>     >> all stakeholders,
>>>>>>>     >>             including
>>>>>>>     >>                         governments among others.
>>>>>>>     >>                         Only the outcome of such deliberation
>>>>>>>       will be
>>>>>>>     >> fully legitimate
>>>>>>>     >>             within the
>>>>>>>     >>                         framework of the post-2015
>>>>>>>     >>                         ICANN.
>>>>>>>     >>
>>>>>>>     >>                       > 2. ICANN does not have to leave the
>>>>>>>       US but
>>>>>>>     >> must be located in
>>>>>>>     >>             a place
>>>>>>>     >>                         where the governing law has
>>>>>>>     >>                         certain characteristics, including
>>>>>>>       not having
>>>>>>>     >> the possibiliity
>>>>>>>     >>             that courts
>>>>>>>     >>                         overrule ICANN (or at
>>>>>>>     >>                         least the IRP).
>>>>>>>     >>                       >
>>>>>>>     >>                       > (And, as it happens, the US is not
>>>>>>>       such a
>>>>>>>     >> place....)
>>>>>>>     >>                       >
>>>>>>>     >>
>>>>>>>     >>                         Not only avoiding courts overruling
>>>>>>>       relevant
>>>>>>>     >> outcomes of the
>>>>>>>     >>             Internet global
>>>>>>>     >>                         community processes,
>>>>>>>     >>                         but also examining and resolving the
>>>>>>>       possible
>>>>>>>     >>             interferences/conflicts that
>>>>>>>     >>                         might arise for
>>>>>>>     >>                         government representatives being
>>>>>>>       subject to a
>>>>>>>     >> foreign country
>>>>>>>     >>             law simply in
>>>>>>>     >>                         the process of attending
>>>>>>>     >>                         to their regular duties (if they were
>>>>>>>       to be
>>>>>>>     >> fully engaged with
>>>>>>>     >>             ICANN).
>>>>>>>     >>
>>>>>>>     >>                         Quote:
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >> "From the Brazilian perspective the existing structure
>>>>>>>       clearly imposes limits to the participation
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>      ???of governmental representatives, as it is unlikely
>>>>>>>       that a representative of a foreign government
>>>>>>>     >>              w
>>>>>>>     >>                   i
>>>>>>>     >> ll be authorized (by its own government) to formally accept a
>>>>>>>       position in a body pertaining to a U.
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>                         S. corporation."
>>>>>>>     >>
>>>>>>>     >>                         This may be what you're getting at
>>>>>>>       with your
>>>>>>>     >> point 3 below, but
>>>>>>>     >>             I'm not sure
>>>>>>>     >>                         whether the problem is
>>>>>>>     >>                         only the fact that governments have
>>>>>>>       to deal
>>>>>>>     >> with a corporate
>>>>>>>     >>             form/law or
>>>>>>>     >>                         whether it is altogether
>>>>>>>     >>                         the fact that it is a single country
>>>>>>>       law
>>>>>>>     >> without any form of
>>>>>>>     >>             deliberate
>>>>>>>     >>                         endorsement by the other
>>>>>>>     >>                         governments (who also have law making
>>>>>>>       power
>>>>>>>     >> in their respective
>>>>>>>     >>             country just
>>>>>>>     >>                         as the US government).
>>>>>>>     >>
>>>>>>>     >>                         Assuming your reading is correct, and
>>>>>>>       if
>>>>>>>     >> necessary complemented
>>>>>>>     >>             by my
>>>>>>>     >>                         remarks above, I'd be
>>>>>>>     >>                         interested in hearing from you about
>>>>>>>       any
>>>>>>>     >> issues you may see with
>>>>>>>     >>             the BR gov
>>>>>>>     >>                         comments.
>>>>>>>     >>                         Thanks,
>>>>>>>     >>
>>>>>>>     >>                         Mawaki
>>>>>>>     >>
>>>>>>>     >>                       >
>>>>>>>     >>                       > 3. ICANN doesn't have to change its
>>>>>>>       form,
>>>>>>>     >> but it needs a form
>>>>>>>     >>             where
>>>>>>>     >>                         governments are comfortable.
>>>>>>>     >>                       >
>>>>>>>     >>                       > (And, as it happens, the corporate
>>>>>>>       form is
>>>>>>>     >> not such a
>>>>>>>     >>             form....)
>>>>>>>     >>                       >
>>>>>>>     >>                       >
>>>>>>>     >>                       > What am I missing?
>>>>>>>     >>                       >
>>>>>>>     >>                       >
>>>>>>>     >>                       >
>>>>>>>     >>                       > On Sat, 6 Jun 2015, Carlos A.
>>>>>>>       Afonso wrote:
>>>>>>>     >>                       >
>>>>>>>     >>                       >> For the ones who are following the
>>>>>>>       IANA
>>>>>>>     >> transition process:
>>>>>>>     >>             attached
>>>>>>>     >>                       >> please find the comments posted by
>>>>>>>       the
>>>>>>>     >> government of Brazil
>>>>>>>     >>             on June 03,
>>>>>>>     >>                       >> 2015, in response to the call for
>>>>>>>       public
>>>>>>>     >> comments on the
>>>>>>>     >>                       >> CCWG-Accountability Initial Draft
>>>>>>>       Proposal.
>>>>>>>     >>                       >>
>>>>>>>     >>                       >> I generally agree with the
>>>>>>>       comments.
>>>>>>>     >>                       >>
>>>>>>>     >>                       >> fraternal regards
>>>>>>>     >>                       >>
>>>>>>>     >>                       >> --c.a.
>>>>>>>     >>                       >>
>>>>>>>     >>                       >
>>>>>>>     >>                       > --
>>>>>>>     >>                       > A. Michael Froomkin, http://law.tm
>>>>>>>     >>                       > Laurie Silvers & Mitchell
>>>>>>>       Rubenstein
>>>>>>>     >> Distinguished Professor
>>>>>>>     >>             of Law
>>>>>>>     >>                       > Editor, Jotwell: The Journal of
>>>>>>>       Things We
>>>>>>>     >> Like (Lots),
>>>>>>>     >>             jotwell.com
>>>>>>>     >>                       > Program Chair, We Robot 2016 | +1
>>>>>>>       (305)
>>>>>>>     >> 284-4285 |
>>>>>>>     >>             froomkin at law.tm
>>>>>>>     >>                       > U. Miami School of Law, P.O. Box
>>>>>>>       248087,
>>>>>>>     >> Coral Gables, FL
>>>>>>>     >>             33124 USA
>>>>>>>     >>                       >                         -->It's
>>>>>>>       warm here.<--
>>>>>>>     >>                       >
>>>>>>>     >> ____________________________________________________________
>>>>>>>     >>                       >
>>>>>>>     >>                       > You received this message as a
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>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
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>>>>>>>     >>
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>>>>>>>     >>                       >
>>>>>>>     >> ____________________________________________________________
>>>>>>>     >>                       > You received this message as a
>>>>>>>       subscriber
>>>>>>>     >> on the list:
>>>>>>>     >>                       >      governance at lists.igcaucus.org
>>>>>>>     >>                       > To be removed from the list, visit:
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>>>>>>>       http://www.igcaucus.org/unsubscribing
>>>>>>>     >>                       >
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>>>>>>>     >> functions, see:
>>>>>>>     >>                       >
>>>>>>>       http://lists.igcaucus.org/info/governance
>>>>>>>     >>                       > To edit your profile and to find
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>>>>>>>     >>                       >      http://www.igcaucus.org/
>>>>>>>     >>                       >
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>>>>>>>     >> http://translate.google.com/translate_t
>>>>>>>     >>                       >
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>>>>>>>     >>
>>>>>>>        ____________________________________________________________
>>>>>>>     >>             You received this message as a subscriber on the
>>>>>>>       list:
>>>>>>>     >>                  governance at lists.igcaucus.org
>>>>>>>     >>             To be removed from the list, visit:
>>>>>>>     >>                  http://www.igcaucus.org/unsubscribing
>>>>>>>     >>
>>>>>>>     >>             For all other list information and functions,
>>>>>>>       see:
>>>>>>>     >>                  http://lists.igcaucus.org/info/governance
>>>>>>>     >>             To edit your profile and to find the IGC's
>>>>>>>       charter, see:
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>>>>>>>     >>
>>>>>>>     >>             Translate this email:
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>>>>>>>     >>
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>>>>>>>     >>
>>>>>>>        ____________________________________________________________
>>>>>>>     >>             You received this message as a subscriber on the
>>>>>>>       list:
>>>>>>>     >>                  governance at lists.igcaucus.org
>>>>>>>     >>             To be removed from the list, visit:
>>>>>>>     >>                  http://www.igcaucus.org/unsubscribing
>>>>>>>     >>
>>>>>>>     >>             For all other list information and functions,
>>>>>>>       see:
>>>>>>>     >>                  http://lists.igcaucus.org/info/governance
>>>>>>>     >>             To edit your profile and to find the IGC's
>>>>>>>       charter, see:
>>>>>>>     >>                  http://www.igcaucus.org/
>>>>>>>     >>
>>>>>>>     >>             Translate this email:
>>>>>>>     >> http://translate.google.com/translate_t
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >> ____________________________________________________________
>>>>>>>     >> You received this message as a subscriber on the list:
>>>>>>>     >>      governance at lists.igcaucus.org
>>>>>>>     >> To be removed from the list, visit:
>>>>>>>     >>      http://www.igcaucus.org/unsubscribing
>>>>>>>     >>
>>>>>>>     >> For all other list information and functions, see:
>>>>>>>     >>      http://lists.igcaucus.org/info/governance
>>>>>>>     >> To edit your profile and to find the IGC's charter, see:
>>>>>>>     >>      http://www.igcaucus.org/
>>>>>>>     >>
>>>>>>>     >> Translate this email: http://translate.google.com/translate_t
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >>
>>>>>>>     >
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>       ____________________________________________________________
>>>>>>>       You received this message as a subscriber on the list:
>>>>>>>            governance at lists.igcaucus.org
>>>>>>>       To be removed from the list, visit:
>>>>>>>            http://www.igcaucus.org/unsubscribing
>>>>>>>
>>>>>>>       For all other list information and functions, see:
>>>>>>>            http://lists.igcaucus.org/info/governance
>>>>>>>       To edit your profile and to find the IGC's charter, see:
>>>>>>>            http://www.igcaucus.org/
>>>>>>>
>>>>>>>       Translate this email: http://translate.google.com/translate_t
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>
>>>>>> --
>>>>>> A. Michael Froomkin, http://law.tm
>>>>>> Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law
>>>>>> Editor, Jotwell: The Journal of Things We Like (Lots),  jotwell.com
>>>>>> Program Chair, We Robot 2016 | +1 (305) 284-4285 |  froomkin at law.tm
>>>>>> U. Miami School of Law, P.O. Box 248087, Coral Gables, FL 33124 USA
>>>>>>                         -->It's warm here.<--
>>>>>>
>>>>>> ____________________________________________________________
>>>>>>
>>>>>> You received this message as a subscriber on the list:
>>>>>>
>>>>>>      governance at lists.igcaucus.org
>>>>>>
>>>>>> To be removed from the list, visit:
>>>>>>
>>>>>>      http://www.igcaucus.org/unsubscribing
>>>>>>
>>>>>>
>>>>>>
>>>>>> For all other list information and functions, see:
>>>>>>
>>>>>>      http://lists.igcaucus.org/info/governance
>>>>>>
>>>>>> To edit your profile and to find the IGC's charter, see:
>>>>>>
>>>>>>      http://www.igcaucus.org/
>>>>>>
>>>>>>
>>>>>>
>>>>>> Translate this email: http://translate.google.com/translate_t
>>>>>>
>>>>>>
>>>>>> ____________________________________________________________
>>>>>> You received this message as a subscriber on the list:
>>>>>>      governance at lists.igcaucus.org
>>>>>> To be removed from the list, visit:
>>>>>>      http://www.igcaucus.org/unsubscribing
>>>>>>
>>>>>> For all other list information and functions, see:
>>>>>>      http://lists.igcaucus.org/info/governance
>>>>>> To edit your profile and to find the IGC's charter, see:
>>>>>>      http://www.igcaucus.org/
>>>>>>
>>>>>> Translate this email: http://translate.google.com/translate_t
>>>>>>
>>>>>
>>>>>
>>>>> ____________________________________________________________
>>>>> You received this message as a subscriber on the list:
>>>>>      governance at lists.igcaucus.org
>>>>> To be removed from the list, visit:
>>>>>      http://www.igcaucus.org/unsubscribing
>>>>>
>>>>> For all other list information and functions, see:
>>>>>      http://lists.igcaucus.org/info/governance
>>>>> To edit your profile and to find the IGC's charter, see:
>>>>>      http://www.igcaucus.org/
>>>>>
>>>>> Translate this email: http://translate.google.com/translate_t
>>>>>
>>>>
>>>
>>>
>>
>> --
>> A. Michael Froomkin, http://law.tm
>> Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law
>> Editor, Jotwell: The Journal of Things We Like (Lots),  jotwell.com
>> Program Chair, We Robot 2016 | +1 (305) 284-4285 |  froomkin at law.tm
>> U. Miami School of Law, P.O. Box 248087, Coral Gables, FL 33124 USA
>>                         -->It's warm here.<--
>>
>> ____________________________________________________________
>>
>> You received this message as a subscriber on the list:
>>
>>      governance at lists.igcaucus.org
>>
>> To be removed from the list, visit:
>>
>>      http://www.igcaucus.org/unsubscribing
>>
>>
>>
>> For all other list information and functions, see:
>>
>>      http://lists.igcaucus.org/info/governance
>>
>> To edit your profile and to find the IGC's charter, see:
>>
>>      http://www.igcaucus.org/
>>
>>
>>
>> Translate this email: http://translate.google.com/translate_t
>>
>>
>

-- 
A. Michael Froomkin, http://law.tm
Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law
Editor, Jotwell: The Journal of Things We Like (Lots),  jotwell.com
Program Chair, We Robot 2016 | +1 (305) 284-4285 |  froomkin at law.tm
U. Miami School of Law, P.O. Box 248087, Coral Gables, FL 33124 USA
                         -->It's warm here.<--
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