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The ALAC appreciates the radical changes made to the PICDRP in response to the comments of the first draft. The process seems far more appropriate for addressing potential harms caused by a registry’s failure to honour the Public Interest Commitment aspects of their registry agreements. Placing contract enforcement within ICANN and the removing the need to pay for the privilege of reporting a contractual infringement sends a far better message regarding ICANN’s attitude towards contractual compliance. The ALAC particularly supports the concept of taking action against repeat offenders.
However, the ALAC still firmly believes that this process does not address the PUBLIC INTEREST aspect of Public Interest Commitments.
There must be a provision for allowing reports of PIC violations, and particularly substantive PIC violations without the need to demonstrate harm. Possible sources of such reports must include:

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A significant aspect of the PIC is to ensure registrant and Internet user trust in the TLD, and to disallow reports of the perceived loss of that trust greatly lessens the benefit of the PIC, and could serve to make them completely ineffective.

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