Attached are consensus comments of the Commercial & Business Users
Constituency (CBUC), regarding the initial report of the GNSO Working group
on Registration Abuse Policies.

The CBUC supports most of the recommendations in the Initial Report, and
offers specific suggestions to guide the policy development process as it
moves to the next stage.   We have offered suggestions in several areas
where the CBUC agrees, plus two areas of disagreement with the Initial
Report.

Several CBUC members contributed to this working group, including Mike
Rodenbaugh, Mike O'Connor, Martin Sutton, Phil Corwin, and Berry Cobb.  Our
lead rapporteur for developing these comments was Berry Cobb.