All, A number of us have recently been discussing the motion up for a vote next week in Toronto to adopt the Working Group's draft advice letter on Consumer Trust, Consumer Choice and Competition. First, I want to commend the working group on the job that they have done and the meticulous detail incorporated in the letter. I believe that they group did as good of a job as anyone could do to come up with metrics based on their best predictions as to what the future gTLD landscape would look like. At the time that the recommendations were created, and the draft advice letter went out for comment, no one knew the number of applications, types of applications, etc. Now, after the reveal, we have more information about the landscape and believe that the original criteria included in the final advice letter may not be well suited for a large number of gTLD applications (which later will be TLDs). While much of the criteria is extremely relevant towards the open gTLDs, they do not necessarily map well to a large number of the other closed, brand, single-registrant or even geographic based TLDs. Over 1/3 of the applications are for brand TLDs, with many of them being single-registrant TLDs. Some of the criteria included in the measure of consumer choice section of the Final Advice Letter, for example, are not applicable to the brand TLDs and may, in fact, give misleading results when looking at the issue of consumer choice. By way of example, the criteria for consumer choice looks at whether the website clearly discloses the benefits and restrictions of the name space (Section 2.1). This makes sense for open registries, but for a closed TLD (like .neustar), it does not. As a fairly large $2.5 billion public company, if Neustar converted its homepage to http://www.neustar, we would not put anywhere on our home page the benefits/restrictions of .neustar. As a closed TLD, there would be no other registrants other than Neustar itself and using up valuable space on our homepage to even mention why were are using .neustar just would not make sense. In addition, Section 2.3 (gTLD registry benefits and restrictions should be understandable to registrants and users) and 2.12 (geographic diversity of registrants) would also not be applicable to the closed-TLDs or regional TLDs. There are other examples. Therefore, our recommendation is that the Council consider sending back the letter to the Working Group to revise their advice based on the current gTLD application landscape before passing such advice on to the board. If this means bifurcating the advice based on the type of TLD, that may make some sense as well. We do not want the group to be disheartened, because they did an excellent job with the information that was available at the time. We now know more and believe that although the letter presents an excellent starting point, it needs some additional work. We look forward to discussing this further in Toronto. Best regards, Jeffrey J. Neuman Neustar, Inc. / Vice President, Business Affairs 46000 Center Oak Plaza, Sterling, VA 20166 Office: +1.571.434.5772 Mobile: +1.202.549.5079 Fax: +1.703.738.7965 / jeff.neuman@neustar.biz<mailto:jeff.neuman@neustar.biz> / www.neustar.biz<http://www.neustar.biz/>