ICANN stakeholders representing general Internet end-users and sovereign states have had limited participation in the development of the gTLD program;
Most of the problems identified by the At-Large Advisory Committee (ALAC) in its Mexico City Summit declaration of February 2009 related to the new-gTLD program have not been satisfactorily addressed and indeed some have worsened;
Numerous complaints from sovereign states, intergovernmental organizations and other bodies have indicated that law enforcement and public-protection measures in the current design of the gTLD program are insufficient;
The ICANN Board, without suitable rationale, has rejected the Joint Applicant Support Working Group recommendations to reduce costs of new gTLD in developing economies independent of any fixed fund, even though this recommendation was actively supported by ICANN's three main public-interest communities (GAC, ALAC and NCSG) and actively opposed by no communities;
The absence of a staggered release schedule or a fixed timetable for future rounds severely inhibits ICANN's ability to correct errors and assess unintended consequences in the proposed application round;
ICANN has still not convincingly demonstrated the end-user need or benefit of a simultaneous launch of hundreds of new TLDs;
The ALAC supports the introduction of gTLDs but is concerned about the ability of ICANN to protect the interests of Internet end-users as it scales to cope with a massive expansion;

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