Thank you for sending through your proposed Scope of Work and Drafting Team language. I have reviewed the documents, and made some suggestions and comments which are attached (using tracked changes).

On the Scope, I think we need to pull out the different elements of the AoC's language here, because it's pretty rich, and there are numerous elements which we need to understand. In particular, I think that the phrase "promotes consumer trust" deserves some scrutiny - what is meant? who are the relevant "consumer" stakeholders - is this a legal definition of consumer as a sort of non-trading individual, or is it all those who "consume" domain name services, ie all internet users. What elements tend to promote consumer trust? Is it a single thing, or do different factors promote trust, depending on which stakeholder group you are part of?

In other words, I see a large part of this group's task as stakeholder mapping, and identifying legitimate interests. In this way, we can inform ourselves about which are the relevant stakeholders (ie law enforcement and which ever stakeholders we think are contained in the concept "consumer trust"), and how their interests support each other or may be in conflict. If we can identify those conflicts, we can then look back at ICANN's policy and ask to what extent it is successful in meeting those needs.

I'd also like to wave a little flag for benchmarking good practice. There's a lot of ccTLD good practice out there, and it might be worthwhile for this team to catalogue this for the purposes of benchmarking against ICANN's policy.