I also have a conflicting obligation. I agree with Jeff on point 1 below. I am fine with the fees for Community Applications and think that the bar should be high to prevent gaming. Best regards, Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com<http://www.gtlaw.com/> | View GT Biography <https://www.gtlaw.com/en/professionals/t/trachtenberg-marc-h> [Greenberg Traurig Logo] [cid:image002.png@01DBA2FC.FE5D3060] From: Jeff Neuman via SubPro-IRT <subpro-irt@icann.org> Sent: Tuesday, April 1, 2025 11:29 AM To: subpro-irt@icann.org Subject: [SubPro-IRT] Apologies for Call *EXTERNAL TO GT* All, Sending apologies for the call later. I have a conflicting obligation. That said, I put comments into the TLD Type document, mostly on the unexpected added fees for Brands and Communities. These make no sense to me at all. 1. Brands - We are saying they have to pay for an evaluation to see if they are eligible to get a .brand. And then it says they have to pay for a Spec. 9 Code of Conduct Exemption as well....even though the Code of Conduct exemption is embedded in Spec 13 (Section 3). Thus, if they qualify to be a brand TLD, then there is No Need for a separate evaluation OR a separate fee? Sure, if they fail eligibility, then you can ask the applicant if it wants the Spec 9 evaluation and then it pays for that. But if it passes eligibility, then no fee and no separate code of conduct evaluation. 2. Communities - Wow, we are really hitting them hard. Not only are they going have to pay for the CPE, which can be a good chunk of change, but then we are also going to charge them for the privilege of putting their policies into Spec 12. Right now, a provision was added that states that after a Community passes CPE, it needs to pay a Registry Commitment Evaluation fee so that ICANN can figure out what can go into Spec 12. -- [cid:image003.png@01DBA2FC.FE5D3060]