Additional comments. Late last fall a working group was put together that consisted primarily of GA-list participants: RJ Glass Vittorio Bertola Michele Neylon Hugh Dierker Debbie Garside John Levine Jacqueline Morris Lawyer Nirmol Seth Reiss Derek Smythe Jeff Williams Danny Younger This collection of individuals did what the ALAC was unwilling to do, namely, they put together a set of policy recommendations with regard to the RAA (and, of course, the ALAC was more than prepared to take credit for this contribution). Out of the 27 separate recommendations tendered, the ICANN Staff selected only one -- the weakest measure possible that had absolutely no teeth, specifically, the inclusion of a standardized description of registrant rights within the RAA. On behalf of this group let me express my outrage. All through this process we have seen public comments tendered in good faith that were cast aside by the ICANN Staff. Never before have we seen such an outpouring of specific implementable recommendations from the general public, with almost all having been discarded by ICANN Staff. The Staff Analysis of Section F of the Synthesis of Public Comments reads as if it were written by employees in bed with the registrar community. Where is the commitment to protection of the public interest? Where is the respect for the community view? When the next registrar goes bad, absconds with your money, and fails to renew your domain names what provision in the RAA will make the registrant whole? We cannot allow ICANN to get off the hook so easily. We cannot put through yet another tame comment while consumer protections are falling by the wayside with increased regularity. Who anywhere would stand for accreditations being provided to non-existent companies and shell corporations? Who anywhere would tolerate accredited entities actively engaging in cybersquatting? Folks in the ICANN organization love to prattle on about methods to deal with institutional capture... well guess what? ICANN has long been captured by the registries and registrars that exclusively feed its coffers. Whatever they want, they get and the public usually gets screwed. We've talked recently about horrible practices such as front-running. Where are the provisions in the RAA to deal with this menace? When registrars pay for multiple-year registrations and the registrar enters only a single year into the WHOIS record, what RAA provisions will ensure that the registrant is protected should the registrar go under? When a registrar reacts to a customer charge-back by changing the WHOIS record for the registrant's other registrations, what provisions in the RAA will make the registrant whole? When a registrar repeatedly nacks transfer requests and impedes the fair exercise of competition, how is this new RAA protecting the registrant? As you look through the amendments, specific registrant protections are almost non-existent. This is an insult to everyone that has actively participated in this process. The entire point of the exercise was to enhance registrant protections in the wake of the RegisterFly event. Where are those protections? Where was the ICANN consultation with consumer protection organizations? Whatever you do, don't send through the usual tepid ALAC Statement. If there ever was a time that outrage needed to be expressed , this is the moment.