Fellow Councilors: I write to share the Intellectual Property Constituency’s stance on the proposed process for Reverse Adoption of GNSO Policy Recommendations. A copy of the IPC’s comment submitted in January is attached which lays out the IPCs’ position. The IPC doesn’t support this for two main reasons. First, having a formal policy in place at the Council level to unadopt policy recommendations supports and frankly encourages the idea that it’s acceptable to go through the lengthy and costly policy development process only wait so long to actually implement the policy that it’s either no longer fit for purpose (allegedly) or out of date. ICANN policy should be implemented as soon as possible and Council should encourage that—not have a built in off ramp to essentially nullify years of previous work. Second, an unadoption of policy is an issue that should be dealt with in the bylaws and by the empowered community—not by Council. Please review our attached comment for more information. I am certainly available to speak to anyone who has questions. Thanks, Damon J. Damon Ashcraft , P.C. O: 602.382.6389<tel:602.382.6389> | M: 602.510.1640<tel:602.510.1640> dashcraft@swlaw.com<mailto:dashcraft@swlaw.com> SNELL & WILMER swlaw.com<https://us.content.exclaimer.net?url=https%3A%2F%2Fwww.swlaw.com%2F&tenantid...> | LinkedIn<https://us.content.exclaimer.net?url=https%3A%2F%2Fwww.linkedin.com%2Fcompan...> One East Washington Street | Suite 2700 | Phoenix, AZ 85004‑2556 Albuquerque | Boise | Dallas | Denver | Las Vegas | Los Angeles | Los Cabos | Orange County | Palo Alto | Phoenix | Portland | Reno-Tahoe | Salt Lake City | San Diego | Seattle | Tucson | Washington, D.C. This email and any attachments may be confidential and protected by legal privilege. If you have received this message in error, please do not disclose the contents to anyone. Please notify the sender by return email and delete this email as well as any attachments from your system.