Below (and attached) is the comment of ICANN’s Business Constituency (BC), regarding the Draft ICANN Strategic Plan for FY 2021 – 25. The BC welcomes the opportunity to provide comment on the draft ICANN Strategic Plan for FY 2021 – 25. Overall, the BC agrees with the content of the Plan, but notes the following suggestions:. Regarding the Introduction: The BC notes that ICANN is proposing to amend its Vision statement in this next Strategic Plan, therefore it makes sense to acknowledge this somewhere in the Introductory language. On the 6th paragraph and last sentence, BC recommends that a link reference for the mentioned bylaws be provided. Question: What constitutes the global public interest? BC thinks this phrase needs to be defined before it is used. As noted most recently in our Jun-2013 comment to Accountability and Transparency Review Team (ATRT-2), here are the principles and process the BC suggests to define the global public interest for ICANN purposes: The BC has previously recommended a definition for public interest that is limited to the scope of ICANN's mission. Namely, to ensure the availability and integrity of registration and resolution services. But it is not for the BC or the ATRT to define public interest for ICANN. The definition should be derived through a process that is open to the ICANN community and Internet stakeholders – including a prominent role for representatives of governments, which often claim to have unique standing to know what is in the public interest of their citizens. The BC notes the Mission of ICANN has not been changed, and supports this decision. Regarding Strategic Objectives: The BC notes that Strategic Objectives result from a diligent outreach and information gathering process, and generally supports objectives that are surfaced with this level of rigor and diverse input. To the extent there is implicit priority in how ICANN lists these Strategic Objectives, it stands to reason that #3 should be first because that is in itself ICANN’s main remit. However, Strategic Goal 3.4 concerning new gTLDs seems tactical and not strategic, and not consistent with the level of import of other points in this section, particularly in light of the weakness of initial new gTLD impacts. We agree Security is next most important, given the continued abuse of DNS and the resultant lack of trust in, for example, web browsing and email, two globally accessible and pervasive systems built on DNS. Improving the effectiveness of the multi-stakeholder model is clearly a priority. ICANN is rightfully developing a reputation for being slow, combative, and less transparent. Decisions and process in the EPDP are just the latest examples in this regard. As to geopolitical issues, ICANN appears at risk of being marginalized by governments and organizations that wish to increase their influence over internet policy, as evidenced by policies originating out of the EU, China, and Russia. If ICANN truly wants to be a ‘Champion’ of the open internet it surely needs to retain or regain its footing on the global stage. Notwithstanding the opening paragraph in this section, stating a Strategic Objective of financial sustainability incurs moral hazard. One can achieve financial stability by increasing revenue or operating more efficiently. But only the latter involves the true discipline ICANN needs, based on observing spending trends over the 5 years of the prior (current) Strategic Plan. This Objective should be re-worded to reflect only Goal 5.2, and possibly 5.3. To this extent, the BC welcomes the ‘Operating Plan’ which the document states is forthcoming. -- This comment was drafted by Jimson Olufuye, Tim Chen, and Steve DelBianco. It was approved in accord with our charter. -- Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency (BC)