Dear Officer,

Thank you for giving me the opportunity to submit my viewpoints on the following:

"no substantive changes to existing rights protection mechanisms are needed for INGOs; no specific new dispute resolution procedures should be created for IGOs, and clarifying policy guidance is to be developed as to the filing of complaints by IGOs under the existing procedures.".

My viewpoints are as below:

i. GNSO IGO-INGO Access to Curative Rights Protection Mechanisms Policy Development Process (PDP) Working Group has done detailed work on the subject matter.

ii. I have gone through GAC viewpoints since 2012 ( GAC Communique - Toronto to 2018), In GAC advises, that

IGOs are a unique treaty-based institution created by governments under international law. IGOs. The GAC forum is representing governments across the globe. The governments are working for national and international policies to safeguard the interests of their citizens. It is proposed that GAC may take place on board as well before moving ahead on this matter.

iii. The number of public community feedback is very low. even less than the number of GAC members participating in each ICANN forums. ICANN may work on this to increase the number of public community feedback in ICANN PDP processes.

Regards

Syed Iftikhar H. Shah