Colleagues, The Joint Application Support Working Group (JAS-WG) has generalized from "script" to "language" to better accommodate the real needs of communities which "code switch" between two or more languages, and possibly the same or a smaller number of scripts, and includes this as a support selection criteria, along with "need" as a criteria, which includes an inability to pay one or more application fees and subsequent application expenses. The JAS-WG has identified applications for underserved languages, and includes this as a criteria, along with "need" as a criteria, which includes an inability to pay a single application fee and subsequent application expenses. Thus, the proposed benefit of a "bundling" of two or more applications by a single applicant for two or more strings would be to those applicants who are not capable of meeting the several criteria for support proposed by the JAS-WG. A non-exhaustive list of applicants not-qualified for support under the JAS-WG proposal at present are: o applications made from highly developed economies, e.g., by Verisign, located in Reston, VA, for a dozen or more representations of the string "com" under one or more linguistic transformation rules, o applications made for trademarks, e.g., by a trademark holder for a set of two or more trademarked strings, o applications made for brands, e.g., by a brand manager for a set of strings used as brands, o applications made by governments, e.g., a government for two or more strings, o etc. There are reasonable grounds to ask that ICANN modify its one-string, one-application model. It fails to conform to the reality that a very substantial population using domain names in Han Script (Chinese) view the distinct characters of the "Simplified Chinese" reform as interchangeable with the associated "Traditional Chinese" characters. It fails to conform to the reality that some applications will share substantive properties with other applications, and regardless of how the competition policy question of whether Verisign should be allowed additional registries, in its own right or as a "technical registry backend services provider" to captive tenants, the utility of expending fee-based resources two, three, or thirty times to determine if Verisign is technically capable of operating a registry is extremely limited. It fails to conform to the reality that registry continuity, like registry escrow, is a service which is "cheaper by the dozen", and any reasonably diverse "pool" of registry operators can provide "continuity service", whether due to regional infrastructure failure such as earthquake or hurricane, war, or ordinary commercial failure, at negligible cost to the unaffected registry operators. There are, quite simply, several sound reasons _for_ bundling, and from a process perspective, the assumption that each application shall be evaluated independently of all others is, as a problem of method, the single least efficient, highest cost, most wasteful, method to adopt. At best all it can tell the evaluator (ICANN) is that two identical applications can both pass AND fail, which is not a very useful result to the applicant in evaluation, or to ICANN as the evaluation process owner. I have on several occasions asked CEO Paul Twomey and Chairman Peter Dengate Thrush, now CEO Rod Beckstrom and Chairman Peter Dengate Thrush, to redefine an application to be for the resources necessary to avoid harm through the promotion of language loss in plural language markets and communities, rather than to be simply a single string. I wish I could relate that I had a reason to suppose that my requests were carefully considered, but I cannot. However, I will not join Ron Andruff, whom I've worked with on several occasions, most recently on the GNSO's Operations Steering Committee (OSC), GNSO Council Operations Procedures Work Team (GCOT), on GNSO Council operations, and respect highly, or the many others, many of whom I've also worked with in the past and respect highly, as the mechanism proposed is both redundant where linguistic necessity exists, and unrestricted where competition policy concerns remain unaddressed. I see no reason to suppose that Verisign has a right to strings that have some association with "com" in scripts other than Latin, nor that it has a right to a lower cost to apply for such a string than any other applicant for the same, or a "confusingly similar" string (in the SWORD algorithmic sense of forming a contention set), which may be making only one application, intending to independently serve the needs of users of that script, and not the shareholders of the Latin script registries, still not transitioned from monopolies to competitive markets. I participate in the Joint Application Support Working Group (JAS-WG). All errors or omissions in the representation of the current draft work product of the JAS-WG, above, are mine. Eric