I would like to add a comment to flag the problems around maintaining 
adequate domain name registration data, this in the case of ICANN’s 
targeted support for the Internet in Africa, and NCSG’s focus on the 
not-for-profit sector.

Consider South Africa, by ordinary measures the most developed country 
in Africa. Earlier this year the government de-registered over 300 South 
African NGO’s and put an equal number on alert that they are about to 
lose their registration. Without registration the NGO cannot even own a 
bank account. The reason: failure to keep their required document 
filings up to date. If they own a domain name (gTLD or ccTLD) there is a 
high probability that they are not even aware of those registration data 
obligations and a high likelihood that they won’t keep that data current.

As well, think of the nightmare that will arise for registrars, et. al. 
if the civil society groups that are de-listed have one of the new 
domain names where registered status is a requirement. Any policy that 
carries requirements should not be based on the ideal situation, and 
should take seriously subjecting itself to stress testing. As well, 
there is scope for enlightened or unenlightened government policy here 
on the continued ownership of particular gTLD domain names. If, for 
example, .ngo means a registered NGO and registration is lost, who will 
be empowered, or obliged, to act?

Sam L.