Thank you for the link to the draft blog, Alice.

I have a couple of edits to suggest.

First, under the first Principle it says ODRs will be in ‘exceptional circumstances.’ Maybe better to say ‘unforeseen circumstances’ – the ODR being contingent on high thresholds and wide interest is made explicit in the next bullet point in the draft.

And second, under the second Principle maybe the phrase ‘where necessary’ about deferrals should be deleted as not needed – it might even conflict with the notion of ‘practical feasibility’ later in the same sentence.

Thanks again and best wishes,

David

David McAuley

Policy Director

Verisign, Inc.