Attached are comments of the ICANN Business Constituency (BC), regarding the draft report of the SSR Review Team. These are initial comments of the BC on this draft report, which we acknowledge filing during the portion of comment period designated for reply comments. While the BC supports a two-part comment period, we are finding that the time for initial comments should be lengthened. In addition, we believe that comment periods should be extended whenever an ICANN public meeting occurs during the comment period. Public meetings require intense participation for several a days, leaving little time to prepare public comments. A simple solution would be to add 7 days to any public comment period that includes dates of an ICANN public meeting. Steve DelBianco vice chair for policy coordination, BC -- Steve DelBianco Executive Director NetChoice http://www.NetChoice.org and http://blog.netchoice.org +1.202.420.7482