thanks Tony and Wolf… with that, i've gone ahead and submitted the comment. again, sorry about the last minute nature of all this. i'm still wondering how i missed this one… mikey PS -- here's the final version, submitted just now (note the cool use of capital letters and punctuation). To whom it may concern, The ISPCP supports the findings in this issue report and encourages the GNSO Council to proceed with a PDP to better understand the value of uniform provisions to address registration abuse -- and the drawbacks that may result as well. The ISPCP especially supports the idea of developing: - a framework of metrics to measure the extent and trends of registration abuse activity - a benchmark study that can be used to understand the current state of the problem and which can also be used as the basis to evaluate the effectiveness of various registration abuse provisions and policies - an ongoing reporting mechanism that can be used to track changes in the level and nature of registration abuse activity as well as continuously evaluate the effectiveness of changes in policy and practice - an evaluation of the benefit that may be gained by establishing a consistent minimum framework of registration abuse prevention activities and provisions that is applicable across gTLD registries and ICANN-accredited registrars The ISPCP wishes to thank the staff for their efforts, and encourage the GNSO Council to move forward with appropriate policy actions to address the recommendations made in this report. Sincerely, Mikey O'Connor (ISPCP rapporteur) - - - - - - - - - phone 651-647-6109 fax 866-280-2356 web http://www.haven2.com handle OConnorStP (ID for public places like Twitter, Facebook, Google, etc.)