The ICANN Business Constituency (BC) submits the attached comment on the draft Framework for Registry Operators to Respond to Security Threats. (ICANN comment page at https://www.icann.org/public-comments/draft-framework-registry-respond-secur... ) This comment was drafted by Denise Michel. It was approved in accord with the BC charter. — Steve DelBianco Vice chair for policy coordination ICANN Business Constituency