Attached is a draft comment from the BC regarding ICANN's call for comments on New gTLD Registry Agreement (<http://www.icann.org/en/news/public-comment/closed-generic-05feb13-en.htm>link<http://www.icann.org/en/news/public-comment/base-agreement-05feb13-en.htm>). This comment period closes 20-Mar. As discussed on our member call this week, this draft does not propose any changes to previous BC positions. Instead, the attached comment applies prior BC positions to 4 aspects of the proposed new registry agreement: Specification 11: Public Interest Commitments Base Agreement Article 4: Transition of Registry upon termination of Agreement Base Agreement Article 7: Amendments to the Registry Agreement Specification 5: Reserving Country and Territory Names at the Second Level These comments are based upon prior positions adopted by the BC in accordance with its charter. Three BC position documents are cited here: Implementation Improvements request to ICANN Board of Directors and CEO, Feb-2012 (link<http://www.bizconst.org/Positions-Statements/BC%20request%20for%20implementa...>) BC Comments on New gTLD Applicant Guidebook – April 2011 Discussion Draft, May-2011 (link<http://www.bizconst.org/Positions-Statements/BC+on+Final+App+Guidebook+May+2...>) BC Position on Process for Amendments to new gTLD Registry Agreements, Apr-2010 (link<http://www.bizconst.org/Positions-Statements/BC_on_TLD_contract_amendments.p...>) We are taking comments on this draft until midnight 19-Mar and plan to submit on 20-Mar. In my view, there is no requirement for formal voting since the BC is not taking any new positions in this draft. However, if 10% of BC membership proposes written changes to the prior positions expressed here, we'll hold a call to consider changing the BC position. Any vote to change would require a majority vote of BC members. (see Charter section 7.3) -- Steve DelBianco Executive Director NetChoice http://www.NetChoice.org and http://blog.netchoice.org +1.202.420.7482