Dear Sir / Madam The comments below are being submitted on behalf of Blacknight, an Irish based hosting provider, ISP and ICANN accredited registrar. We would first like to thank the ICANN finance team for their co-operation with the broad ICANN community in both providing greater levels of transparency in the published budget documents and their willingness to engage with the community when clarity around expenditure was requested. With respect to the budget as a whole we would urge ICANN to exercise fiscal prudence throughout its operations. We find it odd that ICANN plans to expand its headcount while it also recognises that its revenues are not growing and may be falling in the future. Normal businesses do not hire more staff when their revenues are flat, so this discrepancy warrants further explanation. As others have noted the ICANN staff headcount has mushroomed in the last few years. While some of that increase was definitely warranted it's not convincing that further growth is. We also find it troubling that ICANN continues to spend on projects and programmes that do not have clearly defined KPIs or other means of assessing their success. ICANN needs to ensure that its core competencies are properly funded, so ensuring that the policy development processes receive adequate funding should take precedence over programmes such as the fellowship or NextGen, which do not seem to have clear KPIs. We are therefore pleased to see that there has been a reduction in funding for those programmes. Considering the importance and impact of GDPR on both contracted parties and ICANN org it is worrying that there does not appear to be a specific budget allocation for GDRP related activities. While this comment period is about the budget as a whole and travel funding is but a small part of it, we would ask ICANN to review some of its policies. We understand that some people are granted the right to travel business class due to health reasons and we would not question that. However it is, for example, a bad use of resources that ICANN would fund business class travel for funded travellers on flights within Europe under 4 hours, where most carriers don't even have a "proper" business class cabin. Most businesses apply rules based on length of flights or overall travel. Applying a blanket rule that traveller X should always fly business class for any reason is an odd choice to make. Providing translation and other language services is important for the development of true global internet policy. If participants cannot understand key documents or follow plenary meetings their engagement in policy work will be negatively impacted. So overall we support ICANN's language services work. However we feel that the expenditure should be more targeted. Not every single document needs to be translated into all of the UN languages and ICANN's data should help inform which documents and types of documents are being read in languages other than English. The supply of translation and interpretation services should be based around demand where possible. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ https://blacknight.blog/ https://ceo.hosting/ Intl. +353 (0) 59 9183072 ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265, Ireland Company No.: 370845