Attached is a response from the ICANN Business Constituency (BC) to the Article 29 Working Party Guidance Letter regarding Whois and GDPR (dated of 11-Apr-2018). This comment was drafted by Margie Milam and Mason Cole, with edits by Paul Mitchell, Steve DelBianco, Tim Chen, Alex Deacon, and Zak Muscovitch. Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency<http://bizconst.org/>