My comments about the S-A document 20179247_3 on legal structure:

1] It is not clear who is going to decide about the concepts of designator vs. members (2nd para, page3). Is this an item for the CCWG to resolve?

2] Items (a) & (c) in section "The weaknesses of the proposed structure are as follows." (page 3):

"(a) Requires forming a new entity and on an ongoing basis attending to a set of associated corporate formalities, although those can be fairly minimal;"

" (c) May have some negative impact on operational efficiency due to the functional separation, and the separate legal status will introduce some
additional costs, although those should not be significant."

I suggest to delete the two statements pointed here by an underline/italics. Both statements are seemly subjectives and tend to steer the reader

to think that this will be easy to implement and that it will not be costly. There has not been any deep analysis done on these to support either statement.

-ed

On Sat, Apr 18, 2015 at 1:49 PM, Client Committee List for CWG <cwg-client@icann.org> wrote:

Dear All,

Attached is a summary of the current legal structure under consideration by the CWG. This also includes the CCWG dependencies.

Please let us know if you have any comments or would like to discuss.

Best regards,

Sharon

SHARON FLANAGAN
Partner

Sidley Austin LLP
+1.415.772.1271
sflanagan@sidley.com

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