AS Domain Registry (.as) welcomes the opportunity to comment on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process. The Registry strenuously objects to the idea that 2 character (1 alpha, 1 numeric), as envisioned by Question 2.7.1.e.2, should EVER be introduced as gTLD strings. The reasons for this are detailed in the statements submitted by APTLD, CENTR, and LACNIC, which AS Domain Registry fully support. AS Domain Registry (.as) GDNS, LLC Stephen Deerhake General Manager and Director of Registry Services