The ICANN Business Constituency (BC) submits the attached comments on the draft roadmap for SAC 051 implementation of a replacement protocol for Whois. A general note regarding ICANN comment periods: These are initial comments of the BC on this topic, 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. Submitted by: Steve DelBianco vice chair for policy coordination ICANN Business Constituency