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On the matter of the Independent Objector, critical safeguards of the public interest have either been removed or left out. Rather than a mechanism to prevent applicants and objectors to effect affect outcomes merely by out-spending their opponents, the IO has been re-architected as a tool to allow the introduction of anonymous, unaccountable, opaque objections. Upon analysing the issue ALAC is now strongly of the opinion that role of the Independent Objector must be eliminated. While we understand its reason for creation, the potential for misuse has been made clear; any benefit it might provide will be far outweighed by its invitation for gaming and bullying. The accessibility issues that the IO was designed to address can be fulfilled if the CWG recommendations are implemented. Should the ICANN Board and staff insist -- against the public good -- to implement the IO, they must at least implement all necessary safeguards to prevent the dangers inherent in the current design.

We also note that if the IO is abolished, the significant cost savings possible can and should be achieved, and considered in the cost-recovery analysis of the gTLD gTLDs program.

It is unfortunate that the DAG has regressed rather than progressed since its last iteration. Rather than incorporate important and clear cross-community direction, Board and Staff have dismissed it as inconvenient or too much of a change from inertia that is in the wrong direction. According to the response to community initiative, "risk management" now appears to be a primary policy goal of ICANN -- and, conveniently, a primary obstacle to change.

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