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

Seth Johnson seth.p.johnson at gmail.com
Thu Jun 11 10:34:10 EDT 2015


I see from that last paper that it's a "public-private partnership?"
Uh-oh.  :-)  And a weird one.  I'll try to think about what it does in
light of recourse to rights.

On Thu, Jun 11, 2015 at 10:16 AM, Michael Froomkin - U.Miami School of
Law <froomkin at law.miami.edu> wrote:
>
> 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.<--
>>>>>>>>     >>                       >
>>>>>>>>     >> ____________________________________________________________
>>>>>>>>     >>                       >
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>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>
>>>>>>>>     >>                       >
>>>>>>>>     >> ____________________________________________________________
>>>>>>>>     >>                       > You received this message as a
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>>>>>>>>     >>
>>>>>>>>        ____________________________________________________________
>>>>>>>>     >>             You received this message as a subscriber on the
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>>>>>>>>        ____________________________________________________________
>>>>>>>>     >>             You received this message as a subscriber on the
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>>>>>>>>     >>             To be removed from the list, visit:
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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
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>>>>>>>>     >> 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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>>>>>>>>     >
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>>       ____________________________________________________________
>>>>>>>>       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
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>>>>>>>>
>>>>>>>>
>>>>>>>
>>>>>>> --
>>>>>>> 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
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>>>>>>      http://www.igcaucus.org/
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>>>>>
>>>>
>>>>
>>>
>>> --
>>> 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:
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>>
>
> --
> 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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