ICANN69 WG Review of Public Comments

	A	B	C	D	E
1	Topic 17: Applicant Support Description of Difference: Substantive differences include the following: - For the recommendation related to support beyond the application fee, financial support for ongoing registry fees were removed. - Suggested that a dedicated Implementation Review Team (IRT) (ASP) may be warranted for this topic alone and be constituted of experts in this area. - Added greater detail on outreach and collaboration with local partners to achieve outreach plan. - Added recommendation that the dedicated IRT establish metrics for success (with a non-exhaustive list of potential metrics included). - Added Implementation Guidance that the dedicated IRT consider how to allocate support if the number of qualified applicants exceeds funds. - Added recommendation that ICANN develop a plan for funding the ASP and potentially seek funding partners.
2	#	Contributor	Comment	Notes	Completion Status

3	Support Output(s) as written
4		The following contributors did not provide additional comments: NORID AS; Anthony Lee (Individual); Thomas Barrett (Individual); ZHOU, LiGuo (Individual); Brand Registry Group, Inc; Business Constituency (BC); ARTICLE 19; GMO Brights Consulting Inc.
5	Not ideal but willing to support Output(s) as written
6	1	NCSG	NCSG fully supports: “Recommendation 17.2: The Working Group recommends expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process.” To be fully complete, however, the WG must also “flesh out” other recommendations for applicant support, including non-financial support (education and information) and a better sense of the multiplier and bid credits that will be given to AS applicants to ensure them a fair chance to win a gTLD, even if they are in contention sets with much larger and better-funded companies. We understand this is a shared goal of the WG, and more details and direction are key to ensuring this will happen. In addition, the funds must be made available for Applicant Support very early - so that even early education can be accompanied by funds and support as potential applicants learn about and become interested in application process.
7	2	GeoTLD Group	The GeoTLD Group considers that applications coming from non for profit entities that are entrusted by a diversity of stakeholders and civil society agents to steward a cultural, linguistic and/or geographic identity/community online, such as the model that can be seen in different members of the GeoTLD Group, could be beneficiaries of potential support to ensure their participation in the Program if sufficient need is demonstrated.
8	3	Intellectual Property Constituency (IPC), also supported by PETILLION Law Firm	The IPC supports the spirit and good intentions behind applicant support. However, the IPC urges that any such support does not result in the bringing into existence of non-viable registries who later place second level registrants at risk.	Registries must be viable, meet same standards.
9		The following contributors did not provide additional comments: Afnic; gTLDs Registries Stakeholder Group (RySG)
10	No opinion
11		The following contributors did not provide additional comments: Clement Genty (Individual); Wei Wang (Individual); Yi Zhang (Individual); Xiaodong Lee (Individual); Kun Liu (Individual); Internet Architecture Board; WIPO; Dotzon GmbH; ccNSO Council; Internet Governance Project
12	Do not support certain aspects or all of the Output(s)
13	1	Swiss Government OFCOM	We note that the PDP WG’s Initial Report included a preliminary recommendation that the Applicant Support Program should include coverage of ongoing registry fees, which has since been removed from the final report. We are of the opinion that Applicant Support Program should consider the reduction or elimination of the ongoing ICANN registry fees, at least in part, to expand financial support available to eligible applicants.	Support reduction/elimination of registry fees.
14	2	INTA	Although INTA supports the majority of the Topic 17 Recommendations, INTA suggests that Implementation Guidance 17.7 be clarified such that the restrictions against gaming not apply solely to Applicants getting Applicant Support who prevail in an auction – such restrictions should apply to this category of supported applicants regardless of how they ultimately secure the right to operate the applied-for TLD (they could just as easily prevail in acquiring the TLD without going to any auction and subsequently transfer to a third-party operator at a cost much lower than a non-supported applicant could have). In addition, the WG may wish to consider instead of elimination or a fixed reduction in registry fees, that a percentage of revenue scheme be adopted that would provide both a shared risk and promise of recovery of some or all normal fees for supported applicants.	Restrictions should apply to all applicants getting Applicant Support.
15	3	Global Brand Owner and Consumer Protection Coalition (GBOC)	Although GBOC supports the majority of the Topic 17 Recommendations, GBOC suggests that Implementation Guidance 17.7 be clarified such that the restrictions against gaming not apply solely to Applicants getting Applicant Support who prevail in an auction – such restrictions should apply to this category of supported applicants regardless of how they ultimately secure the right to operate the applied-for TLD (they could just as easily prevail in acquiring the TLD without going to any auction and subsequently transfer to a third-party operator at a cost much lower than a non-supported applicant could have).	Restrictions should apply to all applicants getting Applicant Support.
16	4	InfoNetworks LLC	While it is important to recognize the Herculean effort that the SubPro Working Group undertook to address a fundamental short coming from the 2012 round, it unfortunately still falls short of addressing the needs of prospective applicants/Registry Operators for emerging and developing economies. This poses a rather fundamental question to ICANN Org of whether it is a global trustee of the Internet's unique identifiers or a quasi trade association for Contracting Parties and the professional consultants and lawyers that service them. As an individual that has provided profession consulting services to Contracting Parties over the last twenty years, I am keenly aware of the danger that ICANN faces of being perceived a mere trade association for contracting parties on the global stage. That is why this aspect of the Applicant Guidebook must be addressed and not merely sweep under the rug on the fears of "gaming" raised largely by portfolio applicants or their consultants.
17	5	ALAC	The ALAC has major concerns with many of the recommendations and implementation guidance which we believe either do not go far enough to improve the utility of ASP and/or suggest “implementation elements of ASP” which lack adequate policy guidance details which are highly necessary. Instead the approach in punting these off to the IRT is disappointing since the implementation phase typically does not incorporate extensive community participation. In particular: • Recommendation 17.1 should include within the ASP framework, a requirement that applicants must demonstrate how they would serve a beneficiary target region or community, not propose merely a general public interest benefit as an evaluation criterion. • Recommendation 17.3 and Implementation Guidance 17.4 should expressly include a reference to business model education (eg. different business case studies) for applicants (as was identified the AM Global Study) to increase the utility of the ASP. • Re: Recommendation 17.5 and Implementation Guidance 17.8, 17.9, 17.1, will a dedicated IRT established / charged with developing implementation elements of ASP – even if giving regard to the JAS WG Final Report and 2012 implementation of ASP – allow for effective community participation and/or input to be incorporated? • Re: Recommendation 17.12 and Implementation Guidance 17.13 ad 17.14, given that the success of the ASP is intrinsically tied to the amount of ASP funds available, we want to know how ICANN org will develop such plan to source for ASP funds. In particular, we believe more concrete steps should be established to secure funding for ASP; that ICANN Org ought to actively inform, encourage and liaise with National banks and aid agencies worldwide to participate in sponsoring applicants or ASP funding; and that request for cooperation by GAC be made, as appropriate. • Re: Recommendation 17.15 and Implementation Guidance 17.16, we are concerned about being asked to support important elements which lack adequate policy guidance details. To be clear, we maintain our proposal to allow an applicant who qualifies for ASP should be given priority in any string contention set, and not be subjected to any further string contention resolution process but note that if 2 or more applicants that qualify for Applicant Support were to be placed in a contention set, then a mechanism is still required to resolve that contention set. In this scenario, and should priority not be given to an applicant that qualifies for Applicant Support, then a version of the Vickrey auction should be the mechanism of last resort where the benefit of a multiplier should apply to bids placed by applicants that receive Applicant Support. • Re: Recommendation 17.18, while we fully support the move to allow applicants that fail ASP evaluation the option to pay balance of full standard application fee and transfer to standard application process, we remain concerned over questions on (i) how SARP’s evaluation methodology will be expanded to include determination of wilful gaming; and (ii) the development of broad agreement on penalty to be applied to applicants found to be wilful gamers.
18	New information or interests that the Working Group has not considered
19	1	gTLDs Registries Stakeholder Group (RySG), Christa Taylor (Individual)	The RySG supports the goals of Applicant Support but notes strongly that every application should be evaluated to ensure the applicant is sufficiently funded and equipped to operate a registry for the long term in a manner that maintains the security and stability of the DNS and is able to implement accepted anti-abuse practices and principles. 17.2 financial support should be clarified and/or expanded upon to include a variety of professional fees (beyond application writing and attorney fees) such as financial viability, securing funding, etc. 17.5 Significant concerns on how bid credits, multipliers, and other features may be used in other unintended ways beyond benefiting AS applicants, and how the risk of gaming can be mitigated. (see 35.2) Applicant Support applicants who have access to bid credits, multipliers, other should be protected from more sophisticated applicants who benefit financially from entering into a business combination or joint venture. 17.9 Metrics should include: a) number of applicants who received bid credits, multiplier, other and were successful in auction; b) number of applicants who withdrew from auction; c) number of applicants who entered in to a business combination or other forms of joint ventures; d) the value of the bid credits, multiplier, other; and e) length of time before any change of ownership occurred. 17.13 The amount of funding should be determined and communicated before the commencement of the application round. This will provide potential applicants with insight on their potential likelihood of success and whether they should apply for funding. It will also provide the information required to 17.14 in seeking additional funding partners without delay. If there are difficulties in attaining the relevant funding, then the weighting of 15.9 (c) should be increased to help fund potential AS in future rounds. 17.17 financial support should include application fees and any related bid credit, multiplier or related benefits received by the applicants. Clarification on any amounts related to 17.2 should be described, i.e., professional services. 17.17 ‘Going out of business’ should be clearly defined to avoid any ambiguity, i.e., where the TLD is unable to meet their financial obligations and unable to secure financing or restructure operations to carry out operations in the short-term.
20	2	Registars Stakeholder Group (RrSG)	Although the RrSG generally supports the Applicant Support Program (ASP), the RrSG would like to ensure that any candidate receiving applicant support meets all of the stringent requirements of the other registries and that they conform to the technical standards. This is necessary to ensure that any registry from the ASP is interoperable with all registrars. The goal of the ASP is to help with some of the needed financial resources and other services, but not at the expense of security and stability of the DNS.	Registries must be viable, meet same standards.
21	3	InfoNetworks LLC	In connection with the original "proof of concept" Round in 2000 when ICANN processed over 40 applications in approximately 3 months(start to finish) one of the Sponsored TLD selected was .MUSEUM. While most will claim it has failed to reach commercial success, it nevertheless serves a small distinct community on the Internet. That Registry today still pays $500 a year in Registry Fees to ICANN, not a $25,000. Of course this Registry Agreement was entered into when ICANN's annual budget was a mere 7 digits.
22	4	ALAC	We have some suggestions related to Implementation Guidance 17.10; if we are expecting uptake to improve then more consideration ought to be given to having established approach, suggest: • Using points earn during evaluation to determine dispersion of funds if there are more applicants than funds • Using “quota per region” approach Separately, the term “Community” is subject to different interpretation by different groups, including evaluators and dispute resolution panelists. It is inherently difficult and unfair to expect an applicant or an objector to accept that a group determined to be a “community” within one aspect of the Program can then be rejected as a “community” in respect of another. An eg. might be an applicant that qualifies for Applicant Support because it has been able to persuade the Support Applicant Review Panel (SARP) that its application target/benefits a community while failing to do the same with a Community Priority Evaluation panelist. We not only support a recommendation that “Community” should be broadly interpreted, but would go further to advocate that the way “community” is interpreted should be applied consistently throughout each aspect of the application process. And, in terms of metrics for the ASP, these should include: • Number of enquiries, number of applications, distribution of applications by jurisdiction, first time/repeats; single vs existing or new portfolios; based on pre-existing trademarks or not • Classification of applications by main categories, distribution by incorporation/private, country, language, scripts etc. • Numbers and responsibilities of ICANN Staff assigned to support applicants - numbers of staff, including out-sourced, assigned to evaluation • Budget available to finance pro-bono assistance, • Third party financing: interest, outreach, T&C, amounts available etc. • Mentorship program participation numbers
23	5	ICANN Board	A. The Board notes that “The Working Group recommends expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process” (Recommendation 17.2). The expansion of applicant support to affirmative payments of costs beyond application fees could raise fiduciary concerns for the Board. We encourage the PDP WG to ensure that applicant support is well scoped by preventing, to the extent possible, the possibility of inappropriate use of resources, e.g. inflated expenses, private benefit concerns, and other legal or regulatory concerns. (Pg. 68) B. Implementation Guidance 17.14 states that “ICANN org should seek funding partners to help financially support the Applicant Support Program, as appropriate.” The ICANN Board notes that this would change the role of ICANN, as ICANN is not a grant-seeking organization. Alternatively, ICANN org – through the Pro Bono Assistance Program – could act as a facilitator in the introduction of industry players or potential funding partners to the prospective entrants.
24	6	GAC	The GAC generally supports the final recommendations on applicant support, noting the importance of extending the scope of the program beyond only economies classified by the UN as least developed and also considering the “middle applicant”. A suggested approach to benefit the “middle applicant” is to reduce the application fee, not to the extent of the reductions availed to underserved regions, so as to encourage “middle applicants” to cross the threshold in the domain namespace. The GAC supports recommendations expanding the scope of financial support to also cover costs such as application writing fees among others. The GAC notes that the cost of a new gTLD extends beyond just the application fee to the cost of the application process as well as running a new gTLD. Interested applicants should be provided with a general estimation of fees and cost that would be required by the whole procedure before the filing of the gTLD application. Furthermore, the GAC urges further consideration on how the Applicant Support Program (ASP) can include the reduction or elimination of the ongoing ICANN registry fees, at least in part, to expand financial support available to eligible applicants, since the Working Group’s Initial Report included a preliminary recommendation to this extent which has been removed from the final report. The GAC highlights the importance of the implementation work as noted in the final report, regarding defining the “middle applicant” and drawing on expertise to develop appropriate program outreach, education and application evaluation. The GAC agrees, as per the GAC Response to ICANN Board Clarification Questions on the GAC Montreal Communique “that expanding and improving outreach should be an ongoing effort, and expects the Board to make a judgment, in good faith, as to whether it considers outreach has been expanded and improved enough to justify proceeding with the new round of gTLDs.” Outreach efforts regarding financial support and fee reduction should primarily target underdeveloped regions, so as to encourage them to cross the threshold in the domain namespace. Further, the GAC notes that there should be separate outreach activities to target “middle applicants” which are located in struggling regions that are further along in their development compared to underserved or underdeveloped regions, which would focus more on how the new gTLDs may practically benefit them against the more awareness-centric outreach programmes for underdeveloped economies and underserved regions. The GAC also recommends community based applicants to be eligible to apply for Applicant Support Program, if the community they represent does not have the resources requested to submit an application, regardless of its country of origin. The GAC also suggests that the ASP can also set up a support system to guide new applicants through the application procedure and deal with all the questions and queries of the applicants about navigating the application process as it can be a daunting task for a first-time applicant. The GAC supports the intention of the recommendations to continue and to expand the applicant support program, and supports a meaningful evaluation of the program to assess its success.	Support reduction/elimination of registry fees.
25	7	ICANN org	Recommendation 17.2: The PDP WG recommends “expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process.” ICANN org suggests that the PDP WG consider a per-applicant limit on the proposed fees and requirements that any such fees covered are both reasonable and based on documented costs incurred. Additionally, it would be helpful for the PDP WG to provide examples of the types of services for which it is recommending attorneys fees be covered, as further information is needed to understand how ICANN payment or support of such fees might be appropriate. ICANN org would also like to seek confirmation whether these fees are to be provided on a reimbursement basis, as eligibility for Applicant Support is determined after submission of an application. The PDP WG may want to consider capturing the proposed fees as part of the pro bono assistance program. Please also refer to the ICANN Board comment on this topic. Recommendation 17.3: This Recommendation appears to conflate policy and Implementation Guidance, as the recommendation is to “improve” a number of activities “as proposed in the implementation guidance below.” An alternative formulation would be: “The Working Group recommends that ICANN conduct outreach, awareness-raising, application evaluation, and program evaluation elements of the Applicant Support Program, considering usability of the program.” The goal of this formulation is to create: (a) A policy requirement which can be clearly assessed as to whether it has been fulfilled and (b) a clearer distinction between the Program requirement and Implementation Guidance. Implementation Guidance 17.6: The PDP WG notes that “outreach efforts should not only target the Global South, but also ‘middle applicants,’ which are located in struggling regions that are further along in their development compared to underserved or underdeveloped regions.” ICANN org would like to understand the PDP WG’s criteria for an applicant to qualify as a “middle applicant,” as well as for “struggling regions.” Additionally, ICANN org notes its understanding that the WG does not recommend limiting outreach to a particular region and intends that the org engage with stakeholders in multiple regions who may not be aware of ICANN and the DNS ecosystem. Implementation Guidance 17.8: Furthermore, on the reference to “targeted regions,” ICANN org understands this in light of the guidance in 17.6 that outreach is not limited to particular regions. Implementation Guidance 17.14: Please refer to the ICANN Board comment on this topic. Recommendation 17.15: This Recommendation states that “if an applicant qualifies for Applicant Support and is part of a contention set that is resolved through an auction of last resort, a bid credit, multiplier, or other similar mechanism must apply to the bid submitted by that applicant.” ICANN org would like to note that Recommendation 17.15 will need further discussion in order to be implementable. One consideration would be that there is perhaps a dissonance between suggesting that an applicant requires support (including direct financial assistance for application drafting, etc.), while also suggesting the applicant should be holding some amount of funds in reserve in order to succeed in an auction. For example, how would these reserve funds be assessed as it pertains to financial assistance qualification? If there is no contention, should that bid amount be accessed? Additionally, it would be helpful to understand if the Applicant Support recipient is expected to pay a specified amount should it succeed in the bidding (any thresholds or percentages). ICANN org also notes that the possibility of auction bid credits might unintentionally encourage use of the Applicant Support Program by those who might not necessarily need financial assistance, as a means to game the system. Implementation Guidance 17.17: Similar to Recommendation 17.15, ICANN org notes that this Implementation Guidance may require further consideration in order to be implementable. The PDP WG notes that “If the Applicant getting Applicant Support prevails in an auction, there should be restrictions placed on the applicant from assigning the Registry Agreement, and/or from any Change of Control for a period of no less than three (3) years.” ICANN org seeks to understand what would happen if the Applicant Support Program (ASP) recipient merges or is acquired during this prohibition period. Would they lose the TLD? Additionally, ICANN org would like to clarify that an Emergency Back-end Registry Operator (EBERO) is a technical backstop and will not trigger an assignment. The PDP WG suggests, “all assignments after such time shall be governed under the then-current Registry Agreement standard provisions; provided that any Assignment or Change of Control after the third year, but prior to the seventh year, shall require the applicant to repay the full amount of financial support received through the ASP plus an additional ten percent (10%).” Org would like clarity whether this Implementation Guidance is solely with respect to ASP auction scenarios or whether this would apply to any ASP recipient that may undergo an Assignment or Change of Control after the third year, but prior to the seventh year. Recommendation 17.18: The PDP WG notes “unless the Support Applicant Review Panel (SARP) reasonably believes there was willful gaming, applicants who are not awarded Applicant Support (whether “Qualified” or “Disqualified”) must have the option to pay the balance of the full standard application fee and transfer to the standard application process.” The PDP WG notes org’s concerns regarding a mechanism or potential penalty to identify and prevent such gaming. ICANN org appreciates the PDP WG’s efforts to address these concerns. It is unclear whether applicants that have been determined by the SARP to have engaged in deliberate gaming will have to reimburse any pro bono work, writing fees or attorney fees that they have received during the application process (Recommendation 17.2). Additionally, in the absence of willful gaming, it would be helpful to understand what happens to the above mentioned pro bono work, writing or attorney fees should an applicant choose to transfer to a standard application.
26	Recommendation 17.2 states: "The Working Group recommends expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process." Question: Should the Applicant Support Program also include the reduction or elimination for eligible candidates of ongoing registry fees specified in Article 6 of the Registry Agreement? If so, how should the financial impact to ICANN be accounted for?
27	Question for Community Input: Recommendation 17.2 states: "The Working Group recommends expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process." Question: Should the Applicant Support Program also include the reduction or elimination for eligible candidates of ongoing registry fees specified in Article 6 of the Registry Agreement? If so, how should the financial impact to ICANN be accounted for?
28	Responses - support reduction/elimination of fees
29	1	Swiss Government OFCOM	We note that the PDP WG’s Initial Report included a preliminary recommendation that the Applicant Support Program should include coverage of ongoing registry fees, which has since been removed from the final report. We are of the opinion that Applicant Support Program should consider the reduction or elimination of the ongoing ICANN registry fees, at least in part, to expand financial support available to eligible applicants.
30	2	dotBERLIN GmbH & Co. KG and Hamburg Top-Level-Domain GmbH	We agree with Recommendation 17.2: "The Working Group recommends expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process." We do not have a position if the Applicant Support Program should also include the reduction or elimination for eligible candidates of ongoing registry fees specified in Article 6 of the Registry Agreement.
31	3	Brand Registry Group, Inc	The BRG would be supportive of extending applicant support towards ongoing registry fees but this would need to be on a case-by-case basis. This should also be time-limited, agreeable in advance. Funding should be drawn from within the Application Support allocated budget.
32	4	ARTICLE 19	We welcome the work of the Working Group regarding this topic. We especially welcome Recommendation 17.2, expanding the scope of financial support provided to Applicant Support Program beneficiaries beyond the application fee to also cover costs such as application writing fees and attorney fees related to the application process. This support is welcome, especially for applicants from the Global South or community organizations and for non commercial exercise of freedom of expression.
33	5	Global Brand Owner and Consumer Protection Coalition (GBOC)	GBOC would support, in principle, a reduction or elimination in ongoing registry fees for Applicant Support-eligible candidates who are ultimately awarded the right to operate the applied-for TLD, subject to a possible cost-recovery for ICANN based on some kind of revenue-sharing by the Applicant (Registry) – perhaps if the registry generates above a certain threshold in revenue over a given period (perhaps quarterly), a portion of such revenue would be shared with ICANN to cover a portion of the reduced or eliminated ongoing registry fees.
34	6	ALAC	Yes, it should. We have expressed above our belief that more concrete steps should be established to secure funding for ASP; that ICANN Org ought to actively inform, encourage and liaise with National banks and aid agencies worldwide to participate in sponsoring applicants or ASP funding; and that request for cooperation by GAC be made, as appropriate. All these steps will help relieve the pressure on ICANN to fully and internally fund the ASP. We also wish to provide input on guardrails for mitigating risk of gaming while increasing the appeal, utility of ASP, to boost overall success of ASP, as follows: Joint financing of Applicant Support applications • ICANN Applicant Support must take account of the overall investment costs necessary for the success of the proposed independent Registry, including how these costs will be financed. • The financial evaluation of the application must be undertaken by qualified staff within ICANN Org. The applicant’s submitted financial data should be kept confidential, except that in the event of joint financing by third party entities (e.g. regional development banks) such data would have to be shared under conditions of confidentiality and with the applicant’s consent. • ‘Portfolio applicants’ or incumbent Registry/ Registrar entities with 10 or more delegated gTLDs (new and legacy) are ineligible to apply for Applicant Support. • To be eligible for Applicant Support, an applicant for: o A geographic name string, must be incorporated in the jurisdiction corresponding to that geographic name, on the basis of prior authorization and regardless of intended use of the string. o A non-geographic name string, must not be incorporated in the jurisdiction considered as tax havens by the OECD. • To implement joint financing, ICANN Org must: a. Undertake a review of the financing of independent gTLD applications arising from the 2012 Round. And publish the anonymised data arising from that review. This is not to be out-sourced. b. Conduct a proactive information and promotional activity with possible third party entities to facilitate subsequent approaches from ICANN and applicants for Applicant Support. c. Establish confidentiality rules and procedures with respect to the sharing of the applicants’ information with third party entities, including all of the applicant’s financial data.
35	7	InfoNetworks LLC	Yes the economics as noted above in the case of .MUSEUM show that ICANN must do more or run the risk of being perceived on the international stage as a mere trade association.
36	Responses - do not support reduction/elimination of fees
37	8	Intellectual Property Constituency (IPC), supported by PETILLION Law Firm	The IPC does not support the elimination of such fees as it does not believe that the ongoing subsidization of registry business models that are not self-sustaining is not in the interests of second level registrants.
38	9	Business Constituency (BC)	No. Applicants must be financially capable of running a registry. Applicants may qualify for assistance in preparing their application but once they sign the registry agreement they should be financially sound and be able to meet the ongoing fee obligations in Article 6. The BC has expressed previously that it does not support subsidizing registry businesses although it does support the application support measures recommended by the Working Group. Please see https://www.bizconst.org/assets/docs/positions-statements/2017/2017_05May_22%20BC%20reply%20to%20questionnaire%20on%20new%20gTLD%20Subsequent%20Procedures.pdf at Page 3.
39	Responses - ICANN Org
40	10	ICANN org	New Issues: The PDP WG has requested “community input on whether the ASP should include the reduction or elimination of ongoing registry fees specified in Article 6 of the Registry Agreement for eligible candidates.” ICANN org would like to note that any Recommendations in this area would require further consideration from an implementation perspective.
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