Hi Anna,

Thanks for flagging this. I have read the proposed policy and it needs serious work. So yes, I think we should submit a public comment on this matter as the NCSG (we cannot as the NCUC) if only because I believe we should provide input into all requests for public comment. However, I am not certain we currently have a common position on this issue. In the months after Marrakech, my recollection is that our GNSO Councillors could not come together and reach a consensus on the proposed changes to ICANN's Expected Standards of Behaviour, and there were good reasons for that. Sooo... we should submit a comment here. But I hope the comment we submit is one which is consistent with the positions for which the NCSG has consistently advocated for; values of due process, procedural fairness, and so forth.