Dear Sir/Madam, On behalf of the RrSG, I would like to submit the comment below on ‘GNSO Operating Procedures and ICANN Bylaws. Kind regards, Zoe Bonython RrSG Secretariat Registrar Stakeholder Group Comment on the GNSO Operating Procedures and ICANN Bylaws This comment is submitted on behalf of the Registrar Stakeholder Group (RrSG). Registrars would like to thank ICANN staff and the Drafting Team (DT) for their work in connection with the revision of the GNSO Operating Procedures and those parts of the ICANN Bylaws pertaining to the GNSO. We believe ICANN staff & the Drafting Team have addressed most of the modifications set forth in the Revised Bylaws. We support the position taken in the proposed GNSO Operating Procedures that the GNSO Council is well equipped to relay the positions of the GNSO Stakeholder Groups and Constituencies. Further, we generally support the voting thresholds proposed for implementation of processes associated with the IANA transition and the parallel process on enhancing ICANN accountability, with one exceptional concern. Our feedback is broken down below. Article 11 Generic Names Supporting Organization We would like to raise a concern regarding Section 11.3 GNSO Council, subsection (j)(ii) and (j)(iii), which state: (ii) GNSO Council Inspection Request as contemplated in Section 22.7: requires an affirmative vote of more than one-fourth (1/4) vote of each House or majority of one House. (iii) GNSO Council Inspection Remedy, as contemplated in Section 22.7 - e, and Stakeholder Group / Constituency Inspection Remedy, as contemplated in Section 22.7 – e(ii) and e(iii), for an inspection requested by the GNSO as a Decisional Participant in the Empowered Community: requires an affirmative vote of more than one-fourth (1/4) vote of each House or majority of one House. We understand that Inspection Requests are defined in the Bylaws as “limited to the accounting books and records of ICANN relevant to the operation of ICANN as a whole, and shall not extend to the underlying sources of such accounting books or records or to documents only relevant to a small or isolated aspect of ICANN's operations or that relate to the minutiae of ICANN's financial records or details of its management and administration (the "Permitted Scope”).” Notwithstanding this definition, it is important to ensure that document inspection is not used to obtain or disclose contractual or sensitive information. The RrSG believes any requests for information related to Registry or Registrar contracts, or information related to their contractual relationships, would qualify as an underlying source and should be excluded. APPENDIX 1: GNSO COUNCIL VOTING RESULTS TABLE Regarding “Approval of a petition to remove a director holding seat 13 or 14” and “Approval of a petition notice to remove a director holding seat 13 or 14” shown on page 43 of the redlined version of the GNSO Operating Procedures, we note the voting thresholds as “>75% of One.” This does not accurately reflect the voting threshold outlined in Art. 11, §3(j)vii and viii. We suggest that table be changed to reflect “>75% of the House that appointed Director” to avoid any confusion.