If no, please explain

Regarding invoicing of fees: In the previous application round, ICANN did not provide Invoices for the application fee(s). However, to be able to deduct payments from revenues, an invoice is essential in many legislations. We kindly request this to be incorporated into the application process this time. Regarding conditional fees: Regarding the estimated conditional fees for CPE we would like to share the following observations: 1. Implementation Guideline 34.4: ICANN org should examine ways to make the CPE process more efficient in terms of costs and timing. Rationale for Implementation Guidance 34.4: The Working Group believes that the CPE process was too costly for applicants, considering that the actual cost incurred by applicants was essentially double compared to what was predicted in the Applicant Guidebook, and further believes that the process took too long to complete. The Working Groups believes that drawing on lessons learned from the 2012 round, the CPE process should be able to realize efficiencies in both costs and time in subsequent rounds. 2. The estimated conditional fees should reflect the Implementation Guidelines, realize efficiencies and proposed fees shall steeply decrease. 3. The estimated conditional fees for CPE should also reflect that efforts to perform CPE are pretty identical to 2012 and at maximum cover the inflation between 2012 and 2026. 4. An compensation of the inflation between 2012 and 2026 is totally understandeable. This compensation would lead to fees of USD 35K-42K (from USD 25-30K in 2012). 5. Under the currently proposed conditional fees for CPE, communities may be discouraged from applying due to the high costs involved. This could have the unintended consequence of forcing communities to choose an alternative string in order to avoid CPE-based contention resolution. We would like to emphasize that CPE should be determined by legitimacy rather than by budgetary constraints. Regarding the estimated conditional fees for geoTLDs we would like to share the following observations: 1. We would like to note that the „New gTLD Subsequent Procedures Final Report“ clearly stated in Affirmation 1.2: „The Working Group affirms Principle A from the 2007 policy and recommends that the New gTLD Program must continue to be administered „in an ongoing, orderly, timely and predictable way“. 2. This affirmation is not reflected in the proposed conditional fee table, as the conditional fees have not yet been fully determined yet. We understand that engaging external contractors presents administrative challenges. However, the Final Report clearly calls for predictability, which is not provided by the current fee ranges. 3. Therefore, we recommend allowing for a shorter comment period for conditional fees once the fee proposals have been made available and discussed with the SubPro IRT. This comment period can take place in parallel with the SubPro IRT’s review of all other comments and should not cause any delay to the opening of the application window. Regarding the Application Refund section we would like to share the following observation: 1. The current refund process proposes a 65% refund on base application fees in the event of early withdrawal. 2. Compared to 80% in 2012 with similar tasks being performed as in 2012, this seems unreasonable. 3. We strongly urge ICANN to re-consider the refund scheme and amend it according to performed tasks.