We filed BC comments on the EWG today (see below and attached). I did make one small edit per David Fares' request; seconded by Marilyn Cade. It's on page 6, giving our position on paying for access for data beyond what is free to the public: (new text in red) Cost recovery for an ARDS model should be split amongst the various groups that benefit from the centralized system. The Registries, for example, could pay a small fee per record as the centralized database is a backup for them. Entities accessing the data could pay a fee for retrieving Gated Access information,which could be done as an upfront cost paid at the time of certification/validation or per request. ICANN could also underwrite the validation/certification costs for Gated Access. The BC believes however, that for domain names use for commercial purposes, as defined and discussed above, basic data elements which identify the registrant should be available to Internet users and consumers without a fee. Additional data elements might require a fee, however these fees should be limited to recovery of actual costs. Thanks to Laura for initial draft and to all who contributed. --Steve From: Steve DelBianco <sdelbianco@netchoice.org<mailto:sdelbianco@netchoice.org>> Date: Friday, September 6, 2013 5:46 PM To: "input-to-ewg@icann.org<mailto:input-to-ewg@icann.org>" <input-to-ewg@icann.org<mailto:input-to-ewg@icann.org>> Subject: Business Constituency comments on Initial Report from the EWG Attached are comments of ICANN's Business Constituency (BC) regarding the Initial Report from the Expert Working Group on gTLD Directory Services. Laura Covington prepared the initial draft and several BC members contributed to the comment before it was properly approved by BC membership on 6-Sep-2013 -- Steve DelBianco Vice chair for policy coordination ICANN Business Constituency