The ICANN Business Constituency (BC) submits the attached comment on the GAC Sub-group draft document for protection of Geographic Names (link<https://gacweb.icann.org/display/gacweb/Governmental+Advisory+Committee>) We hope the attached explanations are sufficient to understand BC objections to the GAC draft document. The BC thanks the GAC for inviting public comments, and we stand ready to engage further with GAC members on this matter. Respectfully, Steve DelBianco Vice chair for policy coordination ICANN Business Constituency