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The At-Large Advisory Committee (ALAC) is extremely disappointed by the latest release of the Proposed Final Applicant Guidebook of November 12, 2010 (PAG). In significant ways its changes reflect a deliberate step backwards, away from transparency and accountability, and towards secrecy and arbitrary action. Even more importantly, the new guidebook fails at any more than cosmetic accommodation of critical, Board-mandated policy work undertaken by ICANN's grass-roots community.

The PAG contains many elements that cause concern. However the At-Large Community, in this response, has chosen to focus on the three most substantive and regressive issues which require our greatest attention.

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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 gTLDs program.

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