The ICANN Business Constituency (BC) submits the attached comment on Internationalized Domain Name (IDN) Implementation Guidelines. ( ICANN comment page at https://www.icann.org/public-comments/idn-guidelines-2017-10-19-en ) This comment was drafted by Andy Abrams, Paul Mitchell, and Olga Yaguez. It was approved in accord with the BC Charter. — Steve DelBianco Vice chair for policy coordination ICANN Business Constituency