Dear Sir/Madam, We kindly send the Amazon Cooperation Treaty Organization comments on the “Public Interest Commitment” regarding the attribution of the Dot Amazon Top Level Domain presented by Amazon Inc. The comments below are for publication in ICANN´s web page https://newgtlds.icann.org/en/applicants/agb/base-agreement-contracting/spec.... We will apreciate to circulate the ACTO comments to the corresponding instances. Best regards, *ACTO* *Comments on the “Public Interest Commitment” regarding the attribution of the Dot Amazon Top Level Domain presented by Amazon Inc. * *Foreword* The Amazon Cooperation Treaty Organization reaffirms the Member Countries’ rejection of the 15 May 2019 decision of the ICANN Board that favored the private company Amazon Inc. on its request for delegation of the top level domain dot amazon. Therefore, the tabling of these comments can not be interpreted otherwise. Additionally, these comments shall be read as a reiteration of all the previous messages, letters, press comuniqués issued on this matter since the beginning of the process not only by ACTO’s Secretary General, but also by the Member Countries. It is important to underscore the “public policy advice of the Governmental Advisory Committee and the principle embodied in the Tunis Agenda for the Information Society, that the policy authority for internet-related public policy issues is the sovereign right of the States”. *Comments* First of all it should be recalled that during the whole process ACTO and its Member Countries have engaged in good faith in the discussions, with a view to finding a mutually agreed solution. The company, on the other hand, showed no flexibility at all, seeming content on running out the clock as if certain that the ICANN Board would hit the gavel in its favor. The stance of ACTO Members has been to safeguard the dot amazon domain in order to protect and promote the Amazon region and its importance to the world. It is our duty to protect “the identity of the Amazon communities and the Amazon region, which has geographic, cultural, simbolic and natural heritage importance to the countries and peoples of the region”, having in mind that the word “Amazon” is internationally used to describe and characterize the Amazon region/basin/biome/river. This is a name with cultural and geographical significance that identifies an area worldly recognized for its ecosystemic functions, that helps sustain Earth’s climatic and environmental balance. With its almost 40 million inhabitants, including several indigenous tribes/peoples, the Amazon region stands for ethnic and cultural diversity, that adds to an enormous biodiversity. Under the Public Interest Commitment proposed by the company Amazon Inc., besides there being no commitment to sharing the governance of the TLD, no protection is afforded to a vast number of terms with public policy importance to the Amazon region, including terms that can cause confusion or mislead the public about matters specific to the Amazon region. For example: - words that denote mountains, valleys, rivers, streams, islands, or any other geographical features with significance that may be located in the Amazon, as well as their cognates in different languages; - words that denote animals, plants, medicinal herbs and other botanical products, or any other expressions of the Amazon biodiversity, as well as their cognates in different languages; - words that denote cities, towns, villages or any other human settlements in the Amazon region, as well as their cognates in different languages; - words that denote general economic, political or cultural activities, such as industry, hotel, tourism, ecotourism, travel, trip, government, education, university, study, research, party, and any other words employed to identify some broad spectrum of socio-economic and political practices or sectors, as well as their cognates in different languages; - words that denote popular festivals, folkloric manifestations, beliefs or religiosity of the Amazon populations, including entities, real or mythological beings related to these activities or manifestations, as well as their cognates in different languages. Therefore, the proposed PIC does not attend to the Amazon Countries public policy interests and concerns. Besides not being the result of a mutually acceptable solution dully endorsed by our countries, it fails to adequately safeguard the Amazon cultural and natural heritage against the the risks of monopolization of a TLD inextricably associated with a geographic region and its populations. *Request* ACTO Member Countries call upon the ICANN Board to not delegate the dot amazon TLD, since delegation as currently proposed would go against both the public interest and GAC’s public policy advice. Alternatively, the ICANN Board should allow further work between ACTO Member Countries and the applicant with a view to finding a mutually satisfactory solution.

From our part, having our April 18 2019 PIC proposal as a win-win baseline, we vow to respect the company’s legitimate commercial interests while safeguarding our principles and public policy concerns.

*************************************************************** *Organización del Tratado de Cooperación Amazónica - OTCA* *SHIS QI 05, Conjunto 16, Casa 21* *Lago Sul, Brasilia - DF Brasil* *Tel. +55.61.32484119*