The ALAC welcomes the Board's efforts to create useful metrics to evaluate the public benefit in the expansion of gTLDs. Our members have been active participants in the GNSO Council Consumer Metrics Working Group(link). This working group had created some useful measurements in its final report (link). However, we are concerned about both its development process, and the metrics reported, especially some of public benefit that were either missing or removed at the demand of contracted parties.

Metrics, by their nature, are neither policy nor implementation but evaluation. The primary intended beneficiaries of the CCCI are end users, who are represented within ICANN by At-large. Yet the task of creating the metrics was left to the GNSO, and as a result the WG report is biased in the interests of ICANN'S own internal communities rather than the public interest. This bias is reflected not by what the WG requests, but what it leaves out:

• Early in the WG's tenure, metrics that were important to At-large were deemed out of scope. We believe then and now that If the public is not well served by TLD expansion, it may choose to bypass new gTLDs completely. We therefore are concerned not only in the choice between different TLDs, but between domain names and other methods of accessing Internet resources (search engines, QR codes, etc). Yet the instance of this serious end-user threat was judged by the WG - over the objections of At-Large members - to be beyond the group's scope. The issue is noted in the preamble of the WG report but is not reflected in any metrics.

• A last-minute intervention by domain industry representatives demanding removal of significant metrics related to "closed" gTLDs disturbed the consensus for the "final" report. The general public is largely unaware of the distinction between closed and open TLDs. We cannot see a distinction in objective. Moreover, we do not believe end users should be expected to learn it. As such, metrics must apply equally to all TLDs that are accessible to any group of end users. We note that the objections of At-Large members of the WG to this change were left out of a report that presents itself as a consensus. The ALAC is troubled by this development, both in the substance of the changes demanded and the abandonment of consensus.

We advise that the metrics ICANN undertakes must not be perceived as deliberately incomplete, lest they be seen as a publicity stunt intended to justify the gTLD expansion after the fact. To this end, they must include measurements that are of value to all Internet end users. As such, the omissions we see are, at best, missed opportunities and at worst, an expensive effort that shall eventually be dismissed as self serving.

We recommend that ICANN accept the CCCI report as partially useful, but of extremely limited public value in its current form. The informational concerns of global end-users must be better incorporated into any ICANN metrics initiative for it to serve its intended purposes.