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The ALAC understands that removing the need to demonstrate harm has the potential for increasing the number of reports that ICANN must respond to, and the ALAC is prepared to work with ICANN to develop reasonable controls to lessen the potential for ICANN devoting unreasonable efforts on addressing capricious or frivolous complaints. To address the need to reasonably limit the resources that ICANN must devote to such cases, it might be acceptable that a single registrant or user report does not trigger a full-blown investigation, but mechanisms must be put in place to ensure that patterns are recognized and swift action is taken if the very trust that the PIC is supposed to engender is does not thereexist. Any such rules must err on the side of welcoming reports of PIC non-compliance, not rejecting them. ICANN has a past history of not being concerned with compliance-related complaints from individuals, and this MUST not be replicated with regard to PICs.

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