Comments On The INTA Application For Recognition As The Domain Name Supporting Organization (A preliminary, partial commentary has already been posted; this is the final version.) Prefatory note: It is out of place for a trademark group to submit such a DNSO application - which includes, among other things, criteria for membership and mechanisms for determining "legitimate" interest in the DNS - since it is questionable whether trademark associations themselves have an interest in the DNS that justifies their inclusion in a DNSO since they represent companies and corporations which themselves form a DNS constitutency that is represented. (Also, see for example the study by M. Mueller [http://istweb.syr.edu/~mueller/study.html] and comments to WIPO of the DNRC [http://wipo2.wipo.int/process/eng/processhome.html]). Viewed in this light, the INTA's proposal for a DNSO may be little more than an attempt on its part to preempt the raising of doubts as to the INTA's own claim to having an interest in the DNS; and any definitions by the INTA of what constitutes legitimate interest in the DNS are therefore suspect, since those definitions will naturally admit the INTA while excluding entities which are in opposition to the INTA on domain names and trademark issues, or which do not recognize a justification for the INTA's participation in the DNSO, or the appropriateness of an application from it. Therefore, while not recognizing the validity of this proposal as such, the following comments are offered on specific articles in it (enclosed between dotted lines below) in order to indicate their incorrectness and perniciousness, because the DNSO might mistakenly consider them in the drafting of its own application. .................................................................... ARTICLE II. OBJECTIVES The objectives of this organization shall be to generally protect and promote the interests of all users of the Internet, and more particularly to disseminate information and make recommendations and policy regarding (1) TLDs; (2) the operation, assignment and management of the domain name system; and (3) other related subjects, including the relationship between trademarks and domain names. The objectives of the DNSO shall be carried out in via means that are open, transparent, and non-discriminatory. ..................................................................... Comments: 1) The first sentence should be changed so that it stops at the word "Internet". As it presently stands, purposes 1, 2, and 3 take precedence over the protection of the interests of all users. 2) Neither the DNSO nor ICANN should have the authority to regulate the relationship between trademarks and domain names, a relationship which it considers artificial and properly left, in those instances in which a conflict may arise between trademark holders and domain name holders, to the civil courts to decide, as they have always done in such cases. The efforts of the INTA and other organizations representing trademark holders to fabricate an identity between trademarks and domain names is an attempt to appropriate domain names for these organizations' commercial use, a purpose for which domain names were never intended and are not properly designed. The phrase "including the relationship between trademarks and domain names" would define the DNSO as an organism for regulating trademark issues, which the DNSO should not be. The DNSO cannot replace the legal instances already in place for this purpose, since it has no mandate from any legislative authority to do so. Such a usurpation of the prerogatives and jurisdiction of the civil authorities constituted for the purpose of trademark controversy resolution would not only put the DNSO in jeapordy of legal action against it but waste its resources unnecessarily, to the detriment of its legitimate, necessary, and urgent functions. The phrase should therefore not be included in an application for a DNSO. ................................................................... ARTICLE III. MEMBERSHIP 1.Classes The Domain Name Supporting Organization ("DNSO") shall be composed of representatives from (1) name registries, (2) registrars of top-level domains ("TLDs") and country code domains ("ccTLDs"), (3) businesses, (4) other entities that are users or have "legitimate" interests involving the Internet, and (5) trademark and anticounterfeiting Interests. ................................................................... Comment: The word "legitimate" should be struck from number 4 of this section as it implies that there are illegitimate interests in the DNS and that one group or sector (in this case, the writers of the proposal) has authority to decide which are those interests. Classes 3 and 5 should not be comprised of the same persons or entities (see Art.IV,1,a below) ................................................................... ARTICLE III. MEMBERSHIP 1.Classes (cont'd) Other Entities that are Users or Have Legitimate Interests Involving the Internet An individual, firm, association or corporation that uses the Internet or has a legitimate interest in the objectives of the DNSO, excluding Name Registries, Registrars, Businesses, and Trademark and Anticounterfeiting Interests, and including, but not limited to, Internet Service Providers, consumers, and consumer groups. .................................................................... Comment: 1) Strike the word "legitimate" (for the reasons given above). 2) Change "the objectives of the DNSO" to "the Domain Name System", because the objectives of the DNSO may not be sufficiently broadly defined, and anyone with an interest in the Domain Name System should be able to join the DNSO. 3) Change "... including, but not limited to, Internet Service Providers, consumers, and consumer groups." to "including, but not limited to, Internet Service Providers, not-for-profit Internet users, independent Internet users, and consumers and consumer groups." The original definition is clearly an attempt by the INTA to exclude the public sector from participation. Furthermore, every independent Internet user who has a domain name thereby has an interest in the Domain Name System. Indeed, it is they who are the foremost users of the Internet and maintain the predominant activity of the Web. .................................................................. ARTICLE III. MEMBERSHIP 1.Classes (cont'd) Definition of Legitimate Interest Any individual, firm, association or corporation having gross revenues of or spending at least $xx in connection with Internet-related activities shall be deemed to have a legitimate interest in the DNSO. The Names Council shall be responsible for determining whether this criterion is met. .................................................................. Comments: Why does this section come after that on "Other entities"? Does the INTA pretend that the "other entites" isn't a legitimate category? If this section, which should not be allowed in any case, had a place in this document, it should come before or after the entire article and not be included as a modification of a particular class. It could just as well be placed after the section on trademark interests, to question their legitimacy. In brief, this is merely another transparent attempt by the INTA to exclude the public sector and the independent users from participation in the DNSO. The whole paragraph should be deleted. Regarding membership selection, see my proposal for a membership Committee, below. .................................................................. Trademark and Anticounterfeiting Interests An individual, firm, or association, excluding name registries, registrars, and businesses, whose primary interest is the protection of trademarks or the effort to stop trademark counterfeiting and infringement. Each Trademark and Anticounterfeiting Interest shall have the right to one vote at the Annual Meeting of the DNSO. .................................................................. Comments: As stated above, lawyers and others who represent business clients having domain names, whether they be trademark law firms or trademark associations, or any other entities who represent domain name holders in legal disputes, have no right to voting participation in the DNSO. Giving it to them would be tantamount to giving my lawyer voting privileges, or the lawyers who represent ISPs, registrars, registries, and other DNS interests membership and voting privileges in the DNSO. Certainly businesses having domain names and who use the Internet have an interest in the domain name system, but under no justification can the lawyers and others who represent them, and in particular who represent them in trademark disputes, also be granted membership. These persons and legal businesses have no interest in the DNS other than their clients', and therefore it is their clients who should be members, not they. This is an effort by brand-name businesses to stack the DNSO with their people ! and control it, and should be stopped. ................................................................... ARTICLE III. MEMBERSHIP 2. Method of Election Each application for membership in the DNSO shall be submitted in writing on a form approved by the Names Council. The application shall require each applicant to submit a statement clearly and concisely documenting the applicant�s (a) involvement with respect to the objectives of the DNSO, and (b) legitimate interests in these objectives. The Names Council shall give prompt consideration to each applicant�s qualification for membership in the class designated and vote upon the application. An applicant must receive the affirmative vote of a majority of the Names Council to be elected to membership. Any applicant not receiving favorable action by the Names Council shall be submitted to the Board of Directors for ICANN for final action. ................................................................... Comments: Strike out the entire section and replace it with the following: Proposal for the Formation and Function of a DNSO Membership Committee. A Membership Committee of the DNSO shall be formed, comprised of one member of the Names Council, who will also act as the Committee's Chairman and report on Committee activities to the Names Council, and one member of each of the Constituencies. The Membership Committee's function will be to review applications for voting membership in the DNSO. The Names Council member of the Membership Committee will act to assure that all applicants for membership in the DNSO fulfill the minimum criteria for membership in the DNSO, for example that they possess a domain name (if that is so decided). The other Committee members will act to assure that applicants have applied with the appropriate Constitutencies, and that they fulfill the Constituencies' minimum requirements for membership. The Committee will circulate applications for membership among its members, or otherwise perform its function, with as little expenditure of time and effort as possible and by employing Internet-based communications. It is further understood that the Committee's function is to include in the DNSO as many entities with an interest in domain names as possible, rather than to exclude any entities or parties by devising restrictive practices or by exerting personal opinion, and that cases of rejection of an application for membership in the DNSO will be unusual, the onus of defending such rejections bearing on the Committee. _______________________________________________________________________ (Comments on the INTA proposal, continued) ...................................................................... Article IV. Names Council. (a) Composition. The Names Council shall be composed of the same classes of membership as the DNSO, and have the following composition: xx members business xx members registries xx members registrars of TLDs xx members users and others xx members trademark and anticounterfeiting interests ....................................................................... Comments: As per the comment to Art.III, 1.Classes (above), if the business and trademark interests classes have the same or predominantly the same members, they would have a disproportionate number of representatives on the Names Council. In effect, no interest should reasonably be able to choose members of the Names Council from more than one Class, as this would give it an unfair advantage in the Names Council. In order to prevent this, no business or other entity should be allowed to vote for members of the Names Council from more than one Constitutency. ....................................................................... (b) Election Names Council members shall be elected only at an Annual meeting of the DNSO. At least xx months prior to said Annual meeting, the Names Council shall set a xx day period in which DNSO members may be nominated for membership to the Names Council, and shall give all DNSO members xx days notice of such nomination period. Only DNSO members from a designated class of membership may be nominated for membership on the Names Council in such membership class, and only DNSO members of such membership class may nominate and vote on such nominee. No DNSO member may nominate more than one Names Council member nominee. All nominations must be submitted to the Board with a statement clearly and concisely documenting the DNSO member�s (a) involvement with respect to the objectives of the DNSO, and (b) legitimate interests in these objectives. Nominations which are either not timely submitted or which fail to provide a legitimacy statement as set forth above shall not be considered by the Names Council. Upon the close of the nomination period, the Names Council shall notify all DNSO members of the nominees for each class of membership. The nominees for each class of membership receiving the majority of the votes therefor shall be elected to such class membership. ................................................................... Comments: The wording of the first section suggests that it is the Names Council which dictates to the members, rather than the other way round. This may seem natural to the INTA, imbued as it is with the corporate mentality, but is anathema to a Supporting Organization of the ICANN. It is not, therefore, the Names Council who will set the nomination period, nor they who will give the membership notice of it. Rather, these logistics should be set in the bylaws or rules of the DNSO, for the Names Council to adhere to quite as well as the membership. Sentence five, beginning "All nominations must...", is wholly inadmissible, for one thing because there is no "Board" (the INTA has made a "Freudian" slip here), and for another because nominations, in a democratic system, cannot be submitted to a council for the election of whose members they are intended, but rather must be submitted to an Election Committee specially designated for the purpose and responsible to the membership. Furthermore, there can be no inquisition of members as to their "involvement with respect to the objectives of the DNSO" or their "legitimate interests in these objectives", as the language of this paragraph calls for. If a person is a member of a constituency of the DNSO, his or her credentials for nominating and voting are already satisfied. This language of the INTA's is not just an insult to the Constitution of the United States and to the character of Internet domain name interests, but is a transparent ploy of the INTA to whitewash their own lack of justification for participating in this process. The rest of the paragraph is superfluous. ....................................................................... (c) Term The term of membership on the Names Council shall be three years, and a member from each class of membership will be elected each year, so that the three-year terms will be staggered. In the first two years, a random drawing shall determine which class of membership initially has members serving one or two year terms. ....................................................................... Comments: Why should this staggering of members' terms be done by classes or constituencies? Since three are elected from each constituency, they can initially be elected for one, two, and three years, respectively. ....................................................................... (d) Meetings The members of the Names Council shall be required to meet at least four (4) times per year. The time and place of this meeting shall be selected by the Chairperson of the Names Council. The place of each meeting shall change to accommodate the international composition of the Names Council. Special or emergency meetings may be held at such times and places (1) as the Names Council may decide, (2) at the call of the Chairperson, or (3) on the written requests of the majority of the member of the Names Council. ....................................................................... Comments: In the last sentence, numbers (1) and (3) are ambiguous. How, after all, should the Names Council "decide" if not by majority vote? (1) should be deleted. A third condition for meeting should be added: (3) by majority vote of the membership of the DNSO. ....................................................................... (e) Vacancies In the event of a Names Council member�s death, resignation, ineligibility or inability to perform the duties of a member of the Names Council, a majority of the Names Council then in office shall have the power to designate a successor to serve for the remainder of the term of such Names Council member. Only a person eligible to serve as a Names Council member shall be eligible for such designation. ....................................................................... Comments: Names Council members should not be designated by the Names Council. Furthermore, there is no need for it. If a member of the Names Council can no longer serve, a new member can be elected by his or her constitutency or class. The Names Council exists to represent the membership, one would suppose, and not the other way round, as the INTA would have it. ....................................................................... (g) Selection of DNSO Representatives for the ICANN Board Pursuant to Article V, Section 4 of the ICANN By-laws, the DNSO is accorded three (3) seats on the ICANN Board. Selection of the DNSO representatives for the ICANN Board shall rest with the Names Council. The Names Council shall ensure that all candidates have a significant understanding of the relationship between the Internet and business practice, intellectual property, free-speech, and consumer protection. Approval of a candidate for the ICANN Board shall require a 2/3 majority vote by the Names Council. ....................................................................... Comments: Selection of the DNSO's representatives on the ICANN Board may be nominated by the Names Council, but their selection should be put to ratification by the DNSO membership in order to ensure a democratic, bottom-up procedure. The whole third sentence should be struck out, as being nothing other than more of the INTA's KGB-like tactics to ensure compliance with their views. What does it mean, after all? That only those members of the Names Council who are in agreement with the policies of the INTA can be designated for the ICANN Board? The INTA will perhaps pardon the DNSO participants for having a certain skepticism as regards the INTA's commitment to free speech and consumer protection. ....................................................................... (i) Task Force The Names Council shall appoint a special task force to research, investigate, and interview potential candidates for the DNSO seats on the ICANN Board. Members of the Task Force shall be selected from the membership of the DNSO. Upon completing a list of candidates, said list shall be forwarded by the Task Force to the Names Council. ....................................................................... Comments: This is more top-down corporatism. If candidates for ICANN Board seats need to be searched out, that job should be alloted to an ICANN Board Nominating Committee, not any "Task Force". As to "investigating" potential candidates, perhaps the INTA would like to entrust that to the FBI? ....................................................................... ARTICLE V. OFFICERS, COUNSEL AND EMPLOYEES Election and Duties The officers of the DNSO shall be a President, who shall also be Chairperson of the Names Council, an Executive Vice President, not more than xx other Vice Presidents, a Secretary and a Treasurer, each of whom shall be elected from DNSO members at the Annual meeting by a majority vote to serve until the next Annual meeting or until a successor shall have assumed the duties of the office. No one shall be eligible to serve successive terms as President. The Names Council may likewise elect such other officers as it may from time to time deem advisable, and they shall perform such duties as the Names Council may prescribe. ....................................................................... Comments: This whole paragraph is not only superfluous but outrageous. The Chairperson of Names Council can simply be elected by the Names Council members. There should be no Vice Presidents, or any other officers with undefined powers for which they have no responsibility to the membership. As to the Names Council selecting further undefined officers on its own without election by the membership and prescribing duties to them, any right-minded person can see where that will lead. All this is in total contradiction to the ICANN bylaws' transparency and accountability rules. ....................................................................... 2. President The President shall preside at all meetings of the DNSO, and shall be the executive head of the DNSO, directly responsible to the Board of ICANN for the conduct of all DNSO operations and activities. The President shall have the authority to delegate to Name Council members or Committee Chairpersons such duties as seem appropriate for the administration thereof under the President�s general supervision. The President shall submit at each Annual Meeting of the DNSO a report of the activities of the DNSO during the proceeding year. ....................................................................... Comments: As was argued above, no President is needed, only perhaps a chairperson selected from the Names Council membership. But even were there to be a President, why in heaven's name should that person be responsible to the Board of ICANN, and how could they be, since they are not one of the ICANN Board members from the DNSO? Regarding this superfluous President's authority, since when does anyone have the right "to delegate to Name Council members or Committee Chairpersons such duties as seem appropriate" to him? That is for the committees to decide, in agreement with the Names Council members they have elected. If the INTA wants to experiment with authoritarian government let them go to South America and see if they can find a dictator who will accomodate them, although there are few left there or anywhere else, save perhaps in the INTA's dreams. ....................................................................... 3. Vice President (blah-blah-blah) ....................................................................... Comment: Strike out all references to Vice-Presidents and other top-down, non-responsible, non-accountable, authoritarian corporate manipulators and controllers. ....................................................................... 5. Treasurer The Treasurer shall have the custody of all monies and securities of the DNSO and shall place same in appropriate financial vehicles and repositories in accordance with guidelines established, at least on an annual basis, by the Names Council. The Treasurer shall keep proper books of account and sign checks and give such surety bonds as the Names Council may require. The Treasurer shall make reports on the financial condition of the DNSO at each Annual Meeting of the DNSO and, whenever called upon to do so, at other meetings of the DNSO and the ICANN Board. The Treasurer shall also perform such other duties as may delegated by the Names Council. All duties performed by the Treasurer shall be subject to the supervision and direction of the Names Council. All financial and other records in the custody of the Treasurer shall be open to the Names Council and the ICANN Board at all times for inspection or audit. On ceasing to hold office, the Treasurer shall surrender all records, files, books of account, monies, securities and other property of the DNSO to a successor or to such other person as shall be designated by the Names Council.. Counsel Unless otherwise directed by the ICANN Board, the Names Council shall retain a Counsel to serve as legal adviser to the Names Council and to hold office until the next Annual Meeting of the DNSO. Counsel shall give such legal opinions as may be requested by the President or the Names Council. ....................................................................... Comments: What are the "financial vehicles" that the INTA is referring to here? Is the INTA prepared to speculate on the stock market with the DNSO's treasury? Note that the INTA does not say here that the financial records of the DNSO shall be open to the membership of the DNSO, but only to the Names Council (and the ICANN Board?). Whenever the books of an organization are not open to its members, it is because there's monkey business afoot. Take a look at the example that Karl Auerbach provided to the IFWP of a non-profit in California whose Board took it completely away from the membership for their personal benefit and advantage, and whose only recourse was to force open the books thanks to a bylaw giving the membership access to them. No separate counsel ("lawyer") should be permitted the Names Council. If the DNSO has to employ lawyers, let these serve for the entire DNSO and not the names Council or the membership separately. As the INTA has it, it is defining the Names Council and the membership as being adversarial. That may be what the INTA wants, but it's no good for the DNSO. ....................................................................... Executive Director The DNSO shall employ a full-time [or part-time] executive with the title Executive Director who shall be the chief staff executive and who shall be responsible to the President and to the Names Council. The employment or discharge of an Executive Director shall be by the Names Council. The Executive Director shall participate in the recommendation, formulation and implementation of policies and programs for the DNSO; shall be responsible for the development and implementation of administrative plans and procedures, for the administrative operation of the office and the supervision of all staff personnel; and shall, in conjunction with the Names Council, develop and implement a budget for the DNSO. ....................................................................... Comments: More authoritarian, unaccountable power for the Names Council. This individual, were he allowed to exist, would, together with the President and Vice-Presidents (according to the INTA's plan), have all the power in the DNSO and be accountable to no one. No, there can be no authorities in any organization related to ICANN that are not elected by and responsible to the membership. This whole paragraph, together with those on the President, the Vice-Presidents, and other superfluous and unaccountable "officers", must be stricken from anything resembling an application or bylaws of the DNSO or any other organism having to do with the ICANN or the Internet. ....................................................................... ARTICLE VI. COMMITTEES Given the importance of having a global consensus on the policies and procedures developed by DNSO, as well as expertise relating to the objectives of the DNSO, the Names Council may create committees for such terms and with such powers and duties, as it shall deem appropriate. The nomination of members to each committee and their election by the Names Council shall be conducted in the same manner as members of the Names Council are nominated under Article IV, except that committee members shall be voted on by the Names Council rather than by DNSO members. Each committee shall have the same class of membership requirements as the DNSO members set forth under Article III. Once formed, each committee shall nominate and vote for a Chairperson from within the committee. The nominee with the most votes shall be elected Chairperson for a term of one year. A Chairperson shall be eligible for re-election for another one-year term, but shall not again be eligible for election as Chairperson for a period of one year thereafter unless nominated for an additional term by a unanimous vote of the committee. The members of each committee shall be appointed for a term of one year, and shall be eligible for re-appointment for two successive subsequent terms of one year each. All committees shall be responsible to the Names Council for the performance of their duties, unless the Names Council shall otherwise direct. The duties of the committees shall be those indicated by their titles or as may be otherwise assigned to them by the Names Council. Regular meetings of each committee may be held without the giving of notice if a day of the week, a time, and a place will have been established by the committee for such meetings. A majority of the members of each committee must be present, either in person or by telephone, radio, television or similar means of communication, at each meeting of such committee in order to constitute a quorum for the transaction of business. The act of a majority of the members so present at a meeting at which a quorum is present will be the act of such committee. Each committee will maintain a record, which need not be in the form of complete minutes, of the action taken by it at each meeting, which record shall include the date, time, and place of the meeting, the names of the committee members present and absent, the action considered, and the number of votes cast for and against the adoption of the action considered. All action by each committee shall be reported to the Names Council at its meeting next succeeding such action for a vote. ....................................................................... Comments: These committees are another mechanism by which the INTA intends to circumvent any accountability to the membership. Notice, in the first paragraph, that they are elected by the Names Council and not by the membership. Notice further that they are not required to keep complete minutes of their meetings, and that they report to the Names Council, which is nowhere required to report on their actions to the membership. None of this can be permitted to occur. ....................................................................... ARTICLE VII. MEETINGS 3. Notice Waiver by a member in writing of notice of a meeting, signed by the member, shall be equivalent to the giving of such notice. Attendance by a member, whether in person or by proxy, at a meeting shall constitute a waiver of notice of such meeting of which the member has had no notice, unless except when the member attends the meeting for the express purpose of objecting, at the beginning of the meeting, to the transaction of any business because the meeting is not lawfully called or convened. ....................................................................... Comments: Perhaps the INTA could explain what they mean by this mumbo-jumbo. ....................................................................... 7. Action by Written Consent Any action required or permitted to be taken at a meeting may be taken without a meeting if consent in writing, setting forth the action so taken, is signed by all necessary members. ....................................................................... Comments: Remove "is signed by all necessary members" and replace with "is signed by all members". We don't want a majority deciding not to have a meeting in order to disenfranchise a minority, do we? (By "we" I mean the DNSO participants, not the INTA, which would seem to want nothing better.) ....................................................................... ARTICE VIII. REMOVAL, SUSPENSION AND EXPULSION 3. Suspension or Expulsion of a Member or Disqualification A member may be suspended for a period or expelled for cause such as violation of any of the By-laws of the DNSO or for conduct prejudicial to the best interests of the DNSO. A member may be temporarily or permanently disqualified from serving as a member for cause, such as violation of any of the By-laws of the DNSO or for conduct prejudicial to the best interests of the DNSO. Suspension, expulsion or disqualification of a member shall be by a two-thirds vote of the entire Names Council, provided that a statement of the charges shall have been mailed to the member under charges at the last recorded address at least fifteen (15) days before final action is to be taken thereon, accompanied by a notice of the time when and place where the Names Council is to take action. The member shall be given an opportunity to be present at the time and place mentioned in such notice and to present a defense, including the right of representation by counsel and the right of cross-examination. ....................................................................... Comments: More McCarthyism, or worse. The Names Council, according to the INTA, will be free to throw anyone out of the DNSO who doesn't agree with them. Also, the language of these paragraphs is insulting and offensive. What does the INTA mean by "charges" and "defense"? Not content with running the DNSO from above and giving all power to unaccountable "executives", here they want to act as judge and jury. This is what comes of having lawyers in the employ of reactionary business interests write the rules for the Internet. This whole section should be eliminated, and replaced with either nothing at all or else some mechanism reflecting the democratic, bottom-up nature of these organizations, for example something similar to Einar Stefferud's Fair Hearing Panels. ....................................................................... ....................................................................... Final note: As stated in the prefatory note, the INTA document is inadmissable as a proposal for a DNSO application to ICANN because it comes from a special interest group which itself has no justifiable claim to being a constituency within the meaning of that term as it relates to interest in the DNS, and because the INTA is no more than a representative of the business interests which already have a constituency. Furthermore, the substance of this document is in such contradiction with the spirit and meaning of the ICANN bylaws, by its blatant refusal to adhere to the rules of accountability and transparency as well as bottom-up democratic process, as to preclude even its consideration as a basis for discussion by the DNSO. In spite of these contradictions, the leadership of the DNSO and its drafting committee have seen fit to not only negotiate with the INTA but to "merge" the DNSO's own application proposal, arrived at through arduous discussion and consensus-making at two international meetings, with the INTA's. The writer of this critique calls on all right-minded people interested in the success of the DNSO's claim to fairly represent the Internet's DNS interests, to refuse to accept this "merger" and to demand that the process of preparing an application representing the community's consensus be reinstated immediately. ______________________________ __________________________________________________ To receive the digest version instead, send a blank email to [EMAIL PROTECTED] To SUBSCRIBE forward this message to: [EMAIL PROTECTED] To UNSUBSCRIBE, forward this message to: [EMAIL PROTECTED] Problems/suggestions regarding this list? 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