The ICANN Business Constituency (BC) submits the attached comment on the Hamilton legal analysis memo regarding GDPR, as of 15-Jan-2018. 

We expect to comment further on compliance models recently posted.

( See ICANN’s Legal Analyses, Proposed Compliance Models, & Community Feedback page at https://www.icann.org/resources/pages/gdpr-legal-analysis-2017-11-17-en )

This comment was drafted by Margie Milam and Tim Chen.

It was approved in accord with the BC Charter.

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Steve DelBianco

Vice chair for policy coordination

ICANN Business Constituency