Dear Sir / Madam These comments are submitted on behalf of Blacknight Internet Solutions Ltd, an ICANN accredited registrar based in Ireland. For the most part we are supportive of the comments submitted on behalf of the RySG, although in common with the RrSG we are not concerned by funding of any subsequent rounds of TLDs. We would also question why ICANN is factoring in revenue from proxy / privacy accreditation when that project is stalled and unlikely to progress in the short to medium term. Why is there no funding for GDPR / privacy related activities in FY20? It is highly unlikely that the ePDP or any related activities to do with GDPR and privacy will be completed in FY19 and there will be a need to fund work in this area in FY20. An overarching concern we would have is that the core functions of ICANN, both policy work and GDD operations be funded adequately. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845