Below and attached is the comment of ICANN’s Business Constituency (BC) regarding the Draft PTI FY21-24 Strategic Plan. The BC appreciates the opportunity to comment on the draft PTI Strategic Plan FY21-24 and we thank the team that put the document together. It is a well-crafted document aimed at aligning PTI operations with the ICANN FY21-25 Strategic Plan and ensuring that PTI focuses on its mandate as the operator of the IANA function of ICANN. Our specific comments and questions on the draft: 1. As with the draft ICANN Strategic Plan FY21-25 for Africa, we would suggest that the Introduction/Background also include a brief description of lessons learnt working with the preceding Interim Strategic Plan introduced after the successful IANA Stewardship Transition of 2016. We would be most interested in lessons learnt with implications for the next four years. 2. Considering that ICANN Strategic Plan FY21-25 is a five-year plan, why is the draft PTI Strategic Plan constrained to four years - one year short of the Plan its aligns with? Perhaps an explanation of the rationale could be provided. 3. Has the impact of COVID-19 Pandemic been factored into the Strategic Plan? If not, we recommend that this be done for a holistic view on the PTI operational horizon. 4. We observe that risks are listed against each strategy with no corresponding mitigating measures outlined. We recommend that mitigation strategies be included. 5. The PTI strengths and weaknesses are not described. We recommend this be included as it would be relevant in assessing appropriateness of the scope of the strategies themselves and gauging PTI’s capacity to implement. This comment was drafted by Jimson Olufuye, Arinola Akinyemi, and Tim Smith. It was approved in accord with our Charter. Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency (BC)