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1. A similar objection mechanism must exist for non-governmental organisations to launch objections (either a better-resourced branch of ALAC, a revised version of the Independent Objector, or something similar)
2. The GAC (and other bodies able to raise objections) should satisfy the broader community that objections it will raise -- as a global advisory body -- reflect a reasonable consensus between members and do not just reflect the whim of a small number of advocates
3. The community must be given due process to "object to the objection", and offer arguments counter to the recommendation to reject a string
4. If the objector does not pay a fee to object, the applicant must not be charged a fee to respond
5. Neither the Board nor ICANN staff can raise an objection without it being vetted by one of the above processes; specifically
6. All objection processes must be transparent; specifically, anonymous objections are explicitly NOT allowed
7. The Board must have ultimate decision making authority with the unimpeded right to override objection advice; as ICANN's Bylaws already allow, it may contract external expertise to advise on principles of international law and treaty
8. Split decisions -- in which even rough consensus between the GAC, ALAC and other stakeholders is impossible -- should weigh in favour of approving the string under objection. Globally blocking a TLD string on public interest grounds requires, in our view, consensus that the very existence of the string damages the public interest.
9. Insult or disrespect alone should not be suitable grounds for a successful objection.

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We support many of the Scorecard's name-protection measures which are consistent with the STI consensus recommendations and even a few that go beyond.

• All of Scorecard #6.1, including #6.1.7.1 so long as such use of the Trademark Clearinghouse does not delay registrations

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• Simplified complaint format (#6.2.2)
• Decisions should not require full panels (#6.2.3)
• Remove reference to "substantive evaluation" (#6.2.4)
• Six month deadline for filing an appeal (#6.2.10.2)
• A

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• successful complainant should have first right of refusal for transfer (#6.2.12)

However, we draw the line at measures that are designed to be punitive to potentially legitimate strings; these are measures in the Scorecard that, in our opinion, are against the public interest and in many cases common sense. In these cases instances we support the ICANN Board's response:

• Elimination of reasonable due process (#6.2.5, 6.2.9)
• Reducing standards of proof to not require "clear and convincing evidence" (#6.2.6)
• Elimination of a requirement of bad faith when determining URS action (#6.2.7)
• A "loser pays" regime (#6.2.8)
• Requirement of a separate rationale for filing of appeal (#6.2.10.1)
• Extend URS beyond exact matches (#6.2.13)
• Lowering standards of proof in Post Delegation Dispute Resolution Procedures (#6.3)

In regard to Consumer Protection measures as stated in Scorecard #6.4 (except for #6.4.4, see below), ALAC strongly agrees with the GAC positions (though we also agree with the "due care" response from the Board related to #6.4.2). At-Large has long indicated to ICANN a dissatisfaction with enforcement efforts, and re-enforces the sentiments behind #4.2.3.

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Extension of the "community" designation to industry sectors (#2.2, 6.4.4): In principle, we endorse the GAC position of wanting a special status for TLD names which indicate entire sectors which may be subject to regulation (such as .bank, .pharma, .lawyer). We are unclear about what form of extended evaluation is expected for such applications, and how the evaluation criteria are to be verified and enforced post-delegation. At-Large members have been following the High Security TLD Working Group and applaud its efforts; however its work seems too highly focused only on the financial services industry and might be overkill for other sectors. We are also concerned about the limits of such a designation; for instance, would ".shop" -- a real application-in-waiting -- be affected, since many countries regulate retail sales? We understand the public-protection aspects of such a recommendation but are unsure if its execution is sufficiently evolved to be implentable without incurring significant delay to the new-gTLD process. Perhaps this "category" of TLD applications only should be delayed until appropriate public-interest concerns and solutions are studied before implementation.

Theme 4: Operational readiness

Scorecard items 3, 6.4

Theme 5: Business and market considerations

Scorecard items 4, 5

Theme 6: Legal considerations

Scorecard items 9, 11

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Geographic names (#8): ALAC supports the rights of political entitles (countries, states, provinces, incorporated cities and counties) to be able to register their names, similarly to trademarks, in the Trademark Clearinghouse, in all appropriate languages and IDN scripts. Anyone wanting to use such names should get appropriate clearances, and be subject to the same name-protection scheme as afforded to trademark owners. However, it is unreasonable for political entities to protect every possible variation (ie, to give the United States government assumed rights to ".america") or colloquial description (is New York entitled to ".bigapple"?). We agree with the ICANN Board response of relying on pre-determined names.

Applicants from developing economies requiring relief: ALAC has long been of firm belief that ICANN should offer a beneficial pricing to applicants who need a rigid criteria regarding location, community service and financial need. We continue to charter and encourage the "JAS" working group to explore ways to reduce barriers within the ICANN application framework and advocate cost reduction for worthy applicants. We reject the role, envisioned by some ICANN stakeholders, that would establish a subsidy fund and/or engage in external fundraising. The effort of ICANN to empower applications from all parts of the world must not be one of charity, it must not pit applicants against each other to demonstrate who is most "worth" for a limited pool of subsidy funds.ICANN staff's refusal to even discuss the concept of differential pricing has hampered attempts to research potential areas of cost saving within the current application framework. And while the Board response to Scorecard # 10 is to await the final work of the JAS, it has already definitively rejected early JAS appeals for lowered pricing. We strongly endorse the GAC's effort to request the ICANN Board to reconsider this regressive and anti-competitive position.

Theme 4: Operational readiness

Scorecard items 3, 6.4

Theme 5: Business and market considerations

Scorecard items 4, 5

Theme 6: Legal considerations

Scorecard items 9, 11

Additional theme: Timing considerations

\[ Possible suggestion of staggering the initial round to release TLDs at, perhaps, three month intervals. This will allow ICANN to more easily ramp up, test technical scalability and enforcement capability, and to reassess costs to enable cost reductions for poor-economy applications \]

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Proposal by Alan Greenberg:

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