Dear Councilors, As mentioned on the call just ended, I have instructions from the ALAC to forward to Council, its position on the issue of protection of IGO/INGO Identifiers. The full version is attached by way of letter, and the shorter version is as follows. The At-Large Advisory Committee (ALAC) wishes to convey its position on this issue of protection of IGO/INGO Identifiers. After having considered the available information, the ALAC stands with the position expressed by the ICANN Board, the IGO/INGO Group spokesperson Brian Beckham and several SubPro IRT members in favouring Option 2 of including the IGO/INGO Identifiers in String Similarity Review. In supporting Option 2, the ALAC places predominance on the following: 1. Firstly, the ALAC recognizes and supports the role of the String Similarity Review (SSR) in helping to mitigate unacceptable risk of end-user confusion and loss of confidence in the DNS due to visually confusingly similar strings being delegated into the Root Zone. This goal should neither be taken lightly nor undermined. Given the status and functions of those IGOs/INGOs in globally advocating for issues and people outside of government, allowing a third party applicant to potentially secure a string that is confusingly similar to a protected IGO/INGO Identifier would not serve the public interest, as it is conceivable that this could lead to bad actors exploiting end-user confusion vulnerabilities to perpetrate harm “in the name of an IGO/INGO”. 2. The ALAC views the inclusion of IGO/INGO Identifiers in SSR, per Option 2, not as an ‘expansion of rights beyond those exact matches of those IGO/INGO Identifiers’ but as the appropriate mechanism to preserve the ability for an IGO/INGO to apply for its relevant identifier if and when it chooses to, as was intended by the relevant policy recommendations from the IGO-INGO PDP. It is inconceivable to the ALAC that policy which exists to protect those IGO/INGO Identifiers for application by their respective IGO/INGO could then be displaced by an unreasonably strict interpretation of policy recommendation text or absence of specific policy recommendation text said to be required to allow implementation by way of Option 2. No policy recommendation exists to suggest that the ability for an IGO/INGO to apply for its protected IGO/INGO Identifier would be encumbered or blocked by a confusingly similar string; or that an IGO/INGO must promptly apply for its IGO/INGO Identifier in order to avoid being blocked by a confusingly similar string/TLD in the next round or future application opportunities. Therefore, *the ALAC urges the GNSO Council to place public interest considerations towards the mitigation of risk of end-user confusion and loss of confidence in the DNS above the call for the strict interpretation of policy recommendation text expressed in Option 1.* *The ALAC would also be supportive of the Third Resolved Clause Option wherein the GNSO Council agrees to instruct the SubPro IRT to refer the issue to the ICANN Board for a decision.* ***** And I would like to reiterate that we should also consider the input from Brian Beckham on behalf of the IGO/INGO group, and whose Identifiers are the very subject of this issue. Kind regards, *Justine Chew* At-Large Advisory Committee (ALAC) Liaison to the GNSO Internet Corporation for Assigned Names and Numbers (ICANN) At-Large website: https://atlarge.icann.org/ ------