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. — Steve DelBianco Vice chair for policy coordination ICANN Business Constituency