My primary motivation in undertaking this review as a member of the DNS
Directorate is to comment on the material in the document from the
perspective of the DNS. This document does not mention the DNS
specifically, and it is relevant to the DNS work in the IETF in the same manner
that this document is relevant to all areas of standardization that fall
within the purview of the IETF.

More generically, as a member of the IETF, I have some small comments that
could be seen as minor nits.

1. In Section 2.3 the text relating to "anyone who is officially
representing the IETF, in any capacity" does not qualify the circumstances
as to when such problematic antitrust behavior is proscribed.  Do the
authors intend this proscription be be in effect only when the individual is
performing their representative duties, or is there an intrention that this
proscription applies at all times to individuals who undertake such
representation tasks? Some clarification in the text may be appropriate
here.

2. In Section 2.3 is says: "the IETF cannot be a forum where participants
engage in problematic antitrust behavior". What is being referred to here? I
_assume_ this means postings to IETF mailing lists, and comments and
comversations in Working group sessions, BOF sessions and plenary sessions
at IETF meetings, including virtual meetings. Is this intended to encompass
the entirety of actions that may occur at an IETF venue, or is it limited to
IETF activities relating to standards-making. Again some clarification might
be helpful here.

3. In Section 4.1 there is a list of "Topics to Avoid". {Perhaps it should
be noted that this list is not intended to be exhaustive, but is
illustrative.

4. "All IETF participants are expected to behave lawfully" While the
document attempts to define "Antitrust law" and "competition law" in terms
of the US and EU juristictions the more generic concept of the prefailing
jurisdiction is not defined, so when the document constrains all
participants be behave "lawfrully" the question is to which laws remains
undefined. A participant participating exclusively by mail in an IETF
activity, and never physically leaving their country of domicile must behave
"lawfully" according to the laws of which jurisdiction?

I had assumed that this draft had already been subject to careful legal
scrutiny, so I am somewhat suprised to observe these nits in this document.