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• The use of the undefined term “good standing” is both vague and inappropriate. If there are criteria under which ICANN will decide to not follow up on a report, they must be clearly stated and subject to appeal.
• There should be no requirement for interaction between a Reporter and Registry if the complaint issues identified in the report are factually identifiable; there is no need to negotiate evidence-based issues.
• Although perhaps obvious to some, it should be explicit that the Standing Panel will include one or more members with clear understanding of Public Interest issues.

Although this document is specifically on the process by which ICANN will address third-party reports on PIC violations, it is essential that ICANN makes it clear that ICANN may as well choose to take action against PIC violations purely on its own accord.

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