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[wg-review] [Version 0.2] Executive Summary [Part II, Appendix]
[Appendix 1] Comments on the DNSO Review Jonathan Weinberg
These are answers to selected questions posed in the DNSO
Review. I am a law professor at Wayne State University. I participated
(while I was a legal scholar in residence at the U.S. Federal
Communications Commission) in an interagency working group as part of the
U.S. government's DNS policymaking process during the period leading up to
the release of the Green Paper. More recently, I was the co-chair of a
working group established by the Names Council to formulate
recommendations regarding the deployment of new generic top-level
domains. The views expressed in these comments, though, are solely my
own; I represent no-one but myself. In particular, I do not and could not
speak for the U.S. government, the Names Council, or the working group.
*IV. DNSO Responsibilities*
*To what extent has the DNSO fulfilled the responsibilities in A,
B and C?*
The DNSO has not fulfilled its policy-development responsibilities
to any meaningful extent, and has played little role in domain name policy
development. On the one hand, Working Group A was able to develop a UDRP
proposal, and the Names Council did approve that proposal. But Working
Group A's plan was the target of considerable criticism on process and
substantive grounds; the Names Council's approval was without extensive
discussion and amounted to a rubber stamp. The ICANN Board reacted by
setting aside the proposal in favor of a different one drafted by a
registrars' group, with the caveat that the new plan would be modified
further by Louis Touton in consultation with persons chosen by ICANN
staff. The final plan owed little to the proposal that emerged from the
DNSO.
With respect to protections for the holders of "famous" trademarks
against the registration of second-level domains similar or identical to
those marks, the DNSO was unable to generate any coherent
recommendations. The Names Council issued a statement, but that
statement had little content. While the Names Council managed to
recommend that "there should be varying degrees of protection for
intellectual property during the startup phase of new top-level
domains," the statement stopped there; it did not speak at all to the
nature and strength of that protection or how it should be achieved.
Finally, when it came to the addition of new generic top-level
domains, the Names Council produced a statement of stunning
generality. ICANN staff were hardly constrained in crafting their own
proposal to the board; they responded by preparing a discussion document
that requested public comment on 74 policy and technical questions that
would have to be answered in connection with the rollout of new
TLDs. Those questions, in turn, were just a subset of those that staff
might have chosen to ask. Almost none of the key policy issues raised by
the deployment of new top-level domains were addressed by the Names
Council; they were left to be decided, either explicitly or sub silentio,
by the ICANN staff and board. Indeed, the key policy decisions relating to
adding new gTLDs, as well as a proposed country code top-level domain for
the European Union, are currently being handled by ICANN staff, under the
supervision of the board, with no DNSO participation.
*Have the policies recommended by the DNSO represented an adequate
consensus of the affected stakeholders? Have the viewpoints of all
stakeholders been considered?*
This question is difficult to answer, because I suspect that the
search for "consensus" in the context of domain-name policy making may be
misplaced. Two key factors have made "rough consensus" a workable
approach in the traditional Internet standards context. First, the
community of Internet engineers and system administrators has been a
relatively small and homogeneous one, bound together by shared values and
professional norms, including respect for technical expertise. Second,
the issues addressed in the consensus process have been technical ones,
and the question whether a proposed solution works has been capable of
resolution via a (relatively) neutral performance metric.
Those factors are not present in the domain name context. The
universe of stakeholders there is large and remarkably diverse. They do
not share common values or professional norms, and many of the interested
parties have strong economic interests in particular outcomes. Moreover,
the questions to be decided largely rest on competing values and competing
claims of right: If the name space is to be limited, how is this limited
resource to be allocated? Should the ability to register domain names be
governed by the first-come-first-served principle, by trademark rules, or
by some other means? Should registries be operated on nonprofit or
for-profit bases? How should we think about companies' sunk investments in
the status quo? These are political issues, not technical ones, and they
cannot be resolved from a pure engineering standpoint, asking which
solution works best. They require value choices. In short, there is no
reason to believe that any genuine consensus can be formed around
domain-name issues. ICANN is proceeding with the deployment of new
generic top-level domains notwithstanding that it has not sought to form
consensus on any implementation point, and likely could not do so if it
tried. Only the desirability of one or more new top-level domains is even
close to common ground.
The Names Council has responded to the need for consensus by
formulating policies on such a high level of generality that most areas of
conflict are avoided. This, however, is not a useful long-term strategy.
Assuming that it is useful for the DNSO to search for consensus,
finally, the Names Council is not well-suited to the task of recognizing
the degree of consensus surrounding any given issue. The problems here
stem from the DNSO's structural flaws, which I will discuss below.
*Have the recommendations been well-defined, useful in terms of
being timely and being structured with a degree of specificity /
flexibility appropriate to achieve practical implementation?*
The Names Council's recommendations on famous marks and new gTLDs
were sufficiently general as to amount to little more than the following
direction to the ICANN Board: "We approve of the careful introduction of
new TLDs, and of some form of startup-phase trademark protection. Go with
our blessing, and decide all of the associated policy questions." It may
be that the Names Council cannot engage in a useful policy-making process
with any greater specificity. But this is a mountain laboring and
bringing forth a mouse. If outputs are to be this abstract, and if almost
all policy decisions are to be made at the Board level in the first
instance, it is not clear that it is worth maintaining the DNSO structure,
and with it, the fiction that domain-name policy making is "bottom up."
*How can the DNSO minimize the amount of subjectivity and increase
the amount of objective consensus building, with it current
structure? With a different structure?*
The question of whether rough consensus is present seems
inherently subjective. The only objective way of gauging the level of
support for a proposal is counting votes; that in turn, though, only
pushes the subjectivity into the determination of who shall be allowed to
vote. One of the Names Council's major areas of subjectivity, as detailed
below, is the allocation of the right to vote within the Names Council.
*V. Structure*
*A. Names Council*
*Is the Names Council fulfilling its responsibility to steer and
manage the DNSO consensus process, or can this be improved?*
The Names Council has so far proved itself incapable of developing
policy. The Council has taken the approach that it should primarily rely
on policy work done by the Working Groups and should ratify the consensus,
where appropriate, that those groups bring forward. Yet where a working
group is unable to reach a conclusion (as with Working Group B), or where
the Names Council is unwilling to endorse a working-group recommendation
(as in the case of Working Group C), the council has been able to say
little. Its members wrangle for several hours at their meetings, adopt a
policy statement at a level of generality high enough to satisfy nearly
all of them, and leave the remaining issues to ICANN staff in the guise of
"implementation." ICANN staff then address the policy issues in the way
they think best.
*Should the NC take a more active role in managing the
consensus-development process, for example by giving working groups more
defined charters and more frequently reviewing the state of their work?*
I doubt that it would be help the process for the Names Council to
seek to micro-manage the working groups. If the Names Council cannot make
effective policy decisions itself, it is unlikely to provide useful
guidance to the working groups. To the extent that the Names Council's
perspective on an issue is sharply different from that of a working group,
it is at least as likely (see below) that the problem derives from the
Names Council being out of touch with the domain-name community as it is
that the working group is nonrepresentatve.
*B. Constituencies*
*Are the constituencies a correct division? Are all DNSO interests
adequately represented in the existing constituency groups? Do the current
divisions aggregate individuals or entities with closely aligned interests
and permit the development of focused positions?*
I agree with Harald Alvestrand that the constituency structure is
"a fundamental reason for the DNSO's problems," a "failure" that "should
be abandoned." As he points out, the constituency structure has generated
underrepresentation, because many interested parties cannot find a home in
any of the approved constituencies; overrepresentation, because other
parties can participate in multiple constituencies; and misrepresentation,
because the selection of constituency representatives obscures significant
differences of opinion within the constituencies.
Certainly, the list of constituencies ICANN selected seems
skewed. There is a considerable overlap, after all, between commercial
entities and trademark interests; on the other hand, individual domain
name holders and ordinary Internet end-users, whom one would think have an
interest in domain name policy development, are not represented on the
Names Council at all. The more basic problem, though, lies not in the
choice of particular constituencies, but in the incoherence of the
underlying structure. Even if nobody were excluded, there would be no
reason to think that we could reflect the views of the domain name
community by identifying a set of activities necessary to, or enabled by,
the domain name system or the Internet in general, collecting industry
actors performing each of the activities on the list, and then giving
equal votes to each group.
The Names Council structure may make more sense if we think of the
Names Council not as a representative body, but rather as consensus-based.
If the idea is that any industry actor represented on the Names Council
should have the power to object to a proposal and thus block consensus,
then relative voting strength becomes unimportant; the only question is
whether every important actor in fact has a Names Council representative
that can exercise its veto. Yet as I noted above, the search for
consensus in domain-name policymaking is probably fruitless. No policy
can gain the support of all affected actors; to demand that is a recipe
for paralysis. If the Names Council is to take any action at all,
therefore, it must be on the theory that its members represents the
domain-name community. Yet there is no reason to think that the NC's
current structure, which drastically under-represents ordinary user
interests, meaningfully reflects the relevant communities.
The list of constituencies included in the Names Council reflects
the political strength of the various actors at the time the institution
was established. That constituency formation process neatly illustrated
the lessons of Mancur Olson's The Logic of Collective Action that is, it
advantaged groups for whom the costs and benefits of domain name policies
were concentrated at the expense of those for whom those costs and
benefits were widely distributed. Over the past eighteen months,
advocates of an individual domain name owners' constituency have sought to
press their case to the Names Council and to the ICANN board. They have
failed so far, notwithstanding that the General Assembly has twice
endorsed the formation of a working group to examine the
constituency. There are two reasons behind this failure. First, absent
enthusiasm for the proposal from major industry players, the Board and the
Names Council have felt no special urgency to move forward. Indeed, it
runs counter to the interests of current Names Council members to dilute
their influence by agreeing to the formation of additional
constituencies. Second, individual domain name holders, each of whom has
only diffuse interests in Internet governance, have little incentive to
join or organize a constituency-in-formation, and therefore group
proponents have not succeeded in organizing individual domain name holders
into any broad-based and representative group onto which the mantle of
"constituency" could fall. Absent effective representation for
individuals, though, together with other measures to reduce the current
Names Council skew in favor of organized commercial interests, it is hard
to argue that the DNSO policy making process represents the domain name
community in any meaningful way.
*Should there be a constituency for individuals, and if so, how
should its membership be constituted?*
*How do you ensure that individuals who choose to form an
individual constituency represent the vast interests of individuals?*
There should be a constituency for individuals. So far,
relatively few individuals have participated in the proposed IDNO. An
important reason why participation has been so low, however, is that so
far it has had no payoff. Individuals do not have constituency status,
and a detached observer might be forgiven for concluding that it is
unlikely that the Names Council and the Board will grant them that
status. Energy expended on participation at this juncture, therefore, is
likely to be in vain. By contrast, if such a constituency were in fact
created, with the ability to elect and instruct Names Council
representatives, I would expect participation to be much more extensive
and more broadly based.
At some level, to demand assurances that an individuals'
constituency will "represent that vast interests of individuals" may place
on this proposed constituency a burden not imposed on the others. It is
hardly clear, for example, that the Business and Commercial constituency
represents "the vast interests of businesses," as opposed to the interests
of the particular businesses who are most active in that constituency's
affairs.
*C. General Assembly (GA)*
*How can the level of participation by constituency members in the
GA be improved?*
*How can the level of participation by GA members in the GA be
improved?*
The General Assembly labors under the handicap of having no
function and no authority. The only function given by the bylaws to the
General Assembly *as a body* is to "nominate, pursuant to procedures
adopted by the NC and approved by the Board," the DNSO members of the
ICANN board. Under the Names Council's procedures, a candidate shall be
deemed nominated if he is endorsed by at least ten members of the General
Assembly. Experience has shown this to be an inconsequential hurdle
Because the GA is powerless, participation in the affairs of the
GA as a body has no payoff. Because participation has no payoff, few
people participate in the GA's discussions. That result is inevitable so
long as the GA, as a body, has no function.
*If changes are made in the constituency structures, and possibly
an individual constituency added, should the GA continue to exist?*
The GA barely exists now. To the extent that the GA is simply a
label for the set of interested persons who may volunteer from time to
time to serve on working groups, etc., then that label can surely continue
to be used. To the extent that the GA is intended to signify an
institution that has have functions and authority *as a body* in the
domain name policy making process, no such institution currently
exists. I think that it would be desirable if such an institution did
exist but we need not worry about abolishing something that doesn't exist
today.
*D. Working Groups*
*Are the working groups an appropriate mechanisms to foster
consensus in the DNSO?*
*Are there mechanisms other than working groups that the NC should
employ in managing the consensus-development process? For example,
assigned task forces?*
The appropriate treatment of working group results presents a
difficult issue. On the one hand, the DNSO working group process can
usefully narrow differences between opposed groups. It makes it possible
for a broad range of participants to participate, and make their expertise
available, in a direct and unfiltered way. On the other hand, because
working groups are self-selected, there is no guarantee that any
particular working group actually reflects the community as a whole.
The Names Council should ask, in each case, for adequate
assurances that a working group was diverse, and that it adequately sought
to collect comments from across the broad range of the community. If
those conditions are met, the Names Council must pay careful attention to
the working group's results. It should not simply dismiss those results
on the basis of its members' intuition that the community consensus lies
elsewhere; it may be the working group, rather than the Council, that is
more closely attuned to community feeling. This point is especially vital
given the Names Council's flaws as a representative body, discussed
above. Assigned task forces do not provide the answer, because they
replicate the failings of the existing constituency structure.
[ Appendix 2] Various Poll Result.
Four topics have been polled by WG members under Greg Burton's volunteer.
(As of Jan. 13)
The poll for 14. Consensus is now published at
http://www.pollcat.com/tzk24p05h3_a
The results are at http://www.pollcat.com/report/tzk24p05h3_a
The poll for 7. Names Council is now up at
http://www.pollcat.com/tzk24l3plu_a
The results are at http://www.pollcat.com/report/tzk24l3plu_a
The poll for 3. Constituencies is still at
http://www.pollcat.com/ty0p1puu4w_a
with results at http://www.pollcat.com/report/ty0p1puu4w_a .
The poll for 4. GA is still at http://www.pollcat.com/ty0p41u8xq_a
with results at http://www.pollcat.com/report/ty0p41u8xq_a .
[Q] Review WG needs more time?
Total number of votes 20 unanimously "YES" with different options for
the working deadline, which was circulated in the Names Council list on Jan
5.
Option A, Feb 20 : 8 members
Option B, March 4 : 10 members
Option C: member's own independent suggetion 2.
Source: Review-WG list: wg-review@dnso.org
[Q] Should our report to the NC focus on consensus or not?
Total number of voters: 33
-calling a vote result just that 25 votes 75.7576%
-try for reporting consensus 8 votes 24.2424%
Source provided by Polling Booth: www.democracy.org.nz/vote1/
[Q] *If* we agree to call a voting result consensus......
Total number of voters: 28
2/3 of the vote 18 votes 64.2857%
90% of the vote 4 votes 14.2857%
Majority 3 votes 10.7143%
Unanimity 3 votes 10.7143%
Source provided by Polling Booth: www.democracy.org.nz/vote1/
[Q] Do you favor the admission to the DNSO of an Individual DN holder's
constituency
Total number of voters: 32
Favour such a constituency 30 votes 93.75%
(distinction
IDNO/IDNH ignored)
Against such a Constituency 2 votes 6.25 %
Source provided by Polling Booth: www.democracy.org.nz/vote1/
[Appendix 3]
[Appendix 4] Joanna Lane's proposal of IDNH Membership
Proposal for Criteria for Membership of DNSO/IDNH
( Basic Model a - a direct GA of individual domain name holders )
1.1.IDNH constituency membership is open to any person who is
an individual domain name holder
1.1 An Individual Domain Name Holder is any person who can demonstrate
a level of control over a specified domain name that a reasonable
person
would conclude grants the individual person the exclusive legal right
to exploit
the specified domain name worldwide subject to applicable laws.
1.2 Examples of items that may be submitted in support of an application
include
but are not limited to
(i) evidence of applicants name on domain contact information
(ii) evidence of applicant's funds used to pay registration fees, if any
(iii) evidence that the applicant may cause the domain name to be
relinquished
(iv) evidence that the applicant is the beneficial holder of any domain name
that
is registered or operated by a third party
(v) Where the applicant does not hold direct control over the domain name,
written evidence must be provided that the controlling party is acting
on instructions
of the beneficial holder and that such instructions may be withdrawn
at the applicants
sole discretion.
ADDITIONAL RULES
1.3 An individual shall not be entitled to more than one membership of IDNH
1.4 Where there is more than one holder of a single domain, that domain
would
not meet criteria for membership.
1.5 No single domain name may be used to support membership of more than
one individual.
1.6 The domain name used to meet criteria for membership shall not be a top
level
domain name or a reserved second level Domain name in registries where
this
level is not open for individual registration.
1.7. Membership is subject to approval by the Committee
(i) The Committee shall be elected by the membership of the IDNH
(ii) Such committee shall examine the totality of the facts.
(iii) Decisions of the committee are final.
(iv) The membership committee shall have three members.
1.9 A person who is a member of another DNSO constituency shall not be
eligible
for full membership of IDNH, but may be invited to contribute to from
time to
time as guest, advisor or consultant.
[Appendix 5] Milton Mueller's Concerns on DNSO Review
1. Communicates to the NC the confusion and disorganization that surrounds
the
concept of "consensus" in the DNSO, and how the inaccurate use of this term
may
actually be counterproductive by fostering manipulation and providing no
clear criteria
for reaching decisions
2. Communicate to the NC the terrible imbalance built in to the constituency
structure,
with business lobbying groups given 4 of the 7 constituencies, and
non-commercial,
educational, civil rights and other interests stuffed together into a single
constituency.
3. Recommends allowing virtually any group of like-minded people to form a
working
group that produces policy recommendations, but finding a way to have the GA
or
some other appropriate forum filter the WG recommendations before they are
passed
up to the NC.
[Appendix 6] Bret Fausset's proposal to Create New Constituecny Procedure
As a consequence, the creation of constituencies is a creature of the
Bylaws, and not something that the DNSO, on its own, can change. You'll see
that under Article VI-B, Section 3(a), constituencies are created by a
majority vote of the Board of Directors:
http://www.icann.org/general/bylaws.htm#VI-B
It's also my belief, and I understand that many on the NC share it, that
petitions for new constituencies can be made directly to the Board and do
not need to go through the Names Council. (I seem to recall Ken Stubbs
making this statement in a General Assembly discussion.) Importantly, the
Bylaws now provide: "Each Constituency shall self-organize, and shall
determine its own criteria for participation...."
Under the current Bylaw structure, a recommendation from this WG that new
constituencies be created would not be sufficient to actually create them --
the recommendation would have to be accompanied by a petition from one or
more self-organized groups, complete with founding members and charters for
participation.
If there's a better way to create new constituencies, I would certainly
expect the Board to look favorably on consensus recommendations from the
DNSO about changes to Article VI-B of the ICANN Bylaws (the section devoted
to the DNSO). But the language in the ICANN Bylaws is the current method.
By the way, I think it would be worth everyone's time to take a quick read
of Article VI-B (linked above) to understand what's "hard-wired" into the
Bylaws and what's susceptible of change by the NC alone. These distinctions
will likely affect the specifics of this WG's report and recommendation. (In
other words, some recommendations will require implementation by the Board
and some will require implementation by the Names Council.)
As for what the procedure is, the Bylaws only state:
Any group of individuals or entities may petition the Board
for recognition as a new or separate Constituency. Any such
petition will be posted for public comment pursuant to Article
III, Section 3. The Board may create new Constituencies in
response to such a petition, or on its own motion, if it
determines that such action would serve the purposes of the
Corporation.
There is no single model for what a constituency petition might look like.
For examples, constituency proponents would want to view the original
constituency proposals (both the successful and the unsuccessful ones) that
were considered by the Board in Berlin and Santiago,
http://www.icann.org/dnso/constituency_groups.html
http://www.icann.org/dnso/noncommpage.htm
together with the Board's resolution approving the constituencies
http://www.icann.org/minutes/minutes-27may99.htm
http://www.icann.org/minutes/minutes-26aug99.htm
As to where a new constituency petition should be directed, I'm not aware of
any statement of preference from the Board and staff as to how to bring such
matters to ICANN's attention. If it were me, I'd send the petition to the
CEO and the Chief Policy Officer, with a copy to members of the Board's
Executive Committee (http://www.icann.org/committees/executive/).
Once submitted, the constituency petition should be posted for public
comment, at which time the NC and other DNSO constituencies will have the
opportunity to review and comment. That, at least under my reading, is how
the process would work under the existing Bylaws.
[Appendix 7] Outreach Report on NCC by Adam Peake
The Names Council Review Task Force questionnaire
<http://www.dnso.org/wgroups/wg-review/Arc02/msg00553.html> asked about
constituency size and countries represented.
Non commercial constituency has 158 member organizations; 63 are large
organizations and 95 small organizations (large membership organizations
are those with more than 1000 members, or more than 200 employees.) In
addition 2 applications a currently (Jan 9. 2001) being processed, 1 large,
1 small.
Non Commercial constituency has members (see
<http://www.glocom.ac.jp/users/ajp/ncmem.html>) from the following
countries:
(note, the constituency doesn't normally list members by country, this list
has not been double checked.)
Albania, Australia, Austria.
Bangladesh, Belgium, Benin, Bolivia, Brazil, Bulgaria, Burkina Faso.
Cambodia, Cameroon, Chile, China, Czech Republic.
Denmark, Dominican Republic.
Ecuador, Egypt, Estonia.
France.
Gabon, Gambia, Germany, Ghana, Greece, Guatemala.
Honduras, Hong Kong.
Ireland, Italy.
Japan, Jordan.
Luxembourg.
Macedonia, Madagascar, Malaysia, Mauritania, Mexico, Moldova.
Nepal, New Caledonia, Netherlands, Nigeria, Niue.
Pakistan, Panama, Peru, Philippines, Poland, Portugal.
Romania.
Singapore, Slovakia, S Korea, Switzerland.
Taiwan, Thailand.
Ukraine, United Kingdom, Uruguay, USA.
Venezuela.
Yugoslavia.
[Appendix 8] registrar.com Position on DNSO
We at register.com commend the DNSO for striving to improve the quality of
the organization. A key issue for the DNSO's focus should be transparency
and accountability in the organization's processes. More transparency, which
includes thorough and effective dissemination of information, would advance
the goals of the DNSO by encouraging broader participation in DNSO
initiatives, creating a greater sense of legitimacy among the DNSO
membership for its actions, and offering well founded policies. Three areas
that would benefit most are projects, budget, and leadership activities.
1. Projects:
Projects undertaken by DNSO working groups and task forces have been most
effective when the goals and processes of the projects are clearly defined.
For instance, a project plan or charter, such as the one posted for Working
Group D (http://www.dnso.org/dnso/notes/19990723.NCwgd.html), establishes a
foundation on which individuals and organizations may plan their involvement
in projects. By informing interested parties of the objectives of the
project and the projected time schedule for key steps in the process, these
parties are able to easily follow the progress of the project, participate
as they feel necessary, and understand how their participation will affect
the process.
Project plans should be published on the website at the outset of a project
and progress summaries should be promptly updated on the website. This is
in addition to their mention on working group discussion lists. If
interested parties have to dig through email lists to get to key pieces of
information, many lose interest and/or trust in the project. Given that,
register.com would offer the following specific suggestions for future
projects:
A. All key documents regarding goals, decisions, and plans for the project
should be published on the website in an easily accessible manner.
B. A clear goals and proposed methods document should be published at the
outset of each project.
C. A detailed timeline of project steps should be published with the goal
document.
D. Realistic timeframes that allow sufficient time for comment and response
at each stage of the process (e.g. a) confirm project goals b) confirm
project method c) first round of proposals.).
2. Budget
Transparency in the budget process would lend additional credibility to the
DNSO, as well as make future voluntary contributions to the budget more
likely. Constituencies would be more enthusiastic about their involvement if
they had a clearer idea how dues were being allocated. Currently, budget
information is posted within the minutes of NC meetings and teleconferences,
as seen in the Scribe's Notes from the NC meeting on November 14, 2000 in
Los Angeles (http://www.dnso.org/dnso/notes/20001114.NCmdr-minutes.html).
While the information presented in such reports is important, it does not
contain sufficient detail nor does it allow an outside reader to know what
is the final or formal budget of the DNSO. A separate, detailed report
would allow constituency members and other interested parties to gain a
better understanding of the DNSO's work. To achieve these objectives,
register.com would like to recommend that:
A. A standing format be developed for reporting DNSO budget information,
including sources of income, itemized expenses, and other relevant
information.
B. This information be presented in an accessible format on the DNSO
website.
3. Leadership Activities
The NC representatives are the public face of the DNSO and have worked hard
to achieve highest level of credibility for the organization. The DNSO
leadership would build upon this spirit of openness by disclosing their
current employment and consulting arrangements and experience as part of
their background materials. The website can be revised to provide such
biographical and professional information
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