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It must be emphasized that, because of the extremely compressed time-line allowed for this response, ALAC has not received as much community feedback that such a statement would normally warrant. While its authors have solicited comment and ALAC endorsement, this statement is still subject to review and possible refinement pending broader At-Large distribution. If the language below is seen as too sharp, the reader is asked to accept our apologies -- but also to understand that we have had both little time and few words with which to express our concerns.

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Regarding extension of the "community" designation to industry sectors (#2.2, 6.4.4): In principle, the ALAC endorses the GAC position of wanting a special status for TLD names which indicate entire sectors which may be subject to regulation (such as .bank, .pharma, .lawyer). We are unclear about what form of extended evaluation is expected for such applications, and how the evaluation criteria are to be verified and enforced post-delegation. At-Large members have been following the High Security TLD Working Group and applaud its efforts; however its work seems too highly focused only on the financial services industry and might be overkill for other sectors. We are also concerned about the limits of such a designation; for instance, would ".shop" -- a real application-in-waiting -- be affected, since many countries regulate retail sales? We understand the public-protection aspects of such a recommendation but are unsure if its execution is sufficiently evolved to be implementable without incurring significant delay to the new-gTLD process. Perhaps this "category" of TLD applications should be delayed until appropriate public-interest concerns and solutions are studied before implementation.

We note that the Board has directed ICANN staff to review some of these issues; the ALAC looks forward to seeing the results of that work

Regarding geographic names (#8): The ALAC supports the rights of political entitles (countries, states, provinces, incorporated cities and counties) to be able to register their names, similarly to trademarks, in the Trademark Clearinghouse, in all appropriate languages and IDN scripts. Anyone wanting to use such names should get appropriate clearances, and be subject to the same name-protection scheme as afforded to trademark owners. However, it is unreasonable for political entities to protect every possible variation (ie, to give the United States government assumed rights to ".america") or colloquial description (is New York entitled to ".bigapple"?). We agree with the ICANN Board response of relying on pre-determined names.

We note the current work progress within the ccNSO on Delegation and Re-Delegation in relation to the matters raised by the Board, and we look forward to seeing the result of that work.

Regarding applicants from developing economies requiring relief (#10): The ALAC has long been of firm belief that ICANN should offer a beneficial pricing to applicants who meet a rigid criteria regarding location, local ownership, community service and financial need. We continue to charter and encourage the "JAS" working group to explore ways to reduce barriers within the ICANN application framework, and advocate cost reduction for worthy applicants. We reject the scenario, envisioned by some ICANN stakeholders, that would establish a subsidy fund and/or engage in external fundraising. The effort of ICANN to empower applications from all parts of the world must not be one of charity, it must not pit applicants against each other to demonstrate who is most "worthy" for a limited pool of subsidy funds.ICANN staff's refusal to even discuss the concept of differential pricing has seriously impeded efforts to research potential areas of cost saving within the current application framework. And while the Board response to (#10) is to await the final work of the JAS, we note that it has already explicitly rejected early JAS appeals for lowered pricing at a previous meeting. We are certain this posture is inimical to the global public interest for an Internet ecology that is representative of the peoples of the world, and we strongly endorse the GAC's effort to request the ICANN Board to reconsider this regressive and anti-competitive position. We also encourage ongoing monitoring of the costs to administer the gTLD program to determine where price reductions may be enabled for these applicants while maintaining general principles of overall cost-recovery (see Theme 4 below).

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