If no, please explain

The wording in Section „1.1 Eligibility“ is inconsistent with other parts of the AGB - e.g. in Topic 27 governments are listed as potential applicants, whereas according to the Applicant journey document they are not listed as eligible applicants. A clarification would be helpful. In section „1.2 Fees“ a clarification might be helpful: those applying for variant gTLDs -> those applying for variants of existing gTLDs.

If no, please explain

In section „2. Conditional Evaluations“ we would like to note that the Community Priority Evaluation (CPE) includes the Evaluation of the Community Registration Policies („Scoring for Criterion 3: Registration Policies“). While we understand that an evaluation of Community Registration Policies against CPE criteria covers not all evaluation criteria against RVCs, we assume that efforts are minimal (=check against the ICANN Bylaws), should be covered by the already high fees for CPE and any additional evaluation fees for Community Registration Policies can be deleted. The Final Report by the SubPro Working Group emphasized the need to foster diversified participation, which should not be made unreasonably difficult. Section „2. Conditional Evaluations“ should include a description and the fees in case an applicant wishes to negotiate the Registry Agreement. Thias is referenced in the document "Applicant Journey 2.11 Contracting": „Applicants who request to negotiate limited amendments to the Registry Agreement will be required to provide a rationale justifying the need for such changes, along with a redline of the requested changes. Applicants are strongly encouraged to inform ICANN as soon as possible in the process. In such cases, additional fees may apply, as described in the [Fees and Payments].“ In section 3.1.3 the current schedule of refunds proposes a 65% refund of applicant fees in the event of early withdrawal. In the previous application round in 2012, applicants could withdraw their application after the first evalutions and still receive a 80% refund. We strongly recommend to maintain this higher refund of 80% particularly in view of the fact that the evaluation will only start afterwards. In order to better understand the ranges of the estimated additional fees, we would like to ask ICANN org to specify the tasks involved.

If no, please explain

In section „1.2. Participation in the Draw“ a proxy is mentioned, this wording has not been introduced before. Does „proxy“ refer to „either of the primary contacts“? If not, a clarification as to who can serve as a proxy would be helpful.

If no, please explain

In section „General“ we propose the following additions: 1. we recommend to specify the wording „Most responses should be several paragraphs but no more than two (2) pages“ to „Responses can be between x and y characters“ and should demonstrate due diligence appropriate for the requested information“. This recommendation increases predictability and clarity for applicants and should be added for all application questions. 2. We recommend to specify if financial fgures can be provided in the currency of the applicants location or if it has to be provided in USD. In sections 1 to 3 we recommend to include information about all current TLDsto better understand existing financial commitments - not only for gTLDs, but also for ccTLDs and sponsored gTLDs: SC1.1-1.2: „That the applicant and/or an affiliate commits to the long-term funding required to operate all of the applicant’s existing gTLDs (if applicable) and newly applied-for gTLD(s).“ This also applies to Q1.2-1, SC2.2-1.2 and Q2-3.1. In self commitment SC4.2-1.2 we recommend to delete the maximum amount. Amounts higher than US$300,000 may be deemed necessary by applicants, depending on their business structure and operating model. The sentence would then read: „SC4.2-1.2: The applicant or QFE entity has at a minimum of US$50,000 plus 25% of the application base fee for each applied-for gTLD in Cash and Cash Equivalents on the balance sheet of the provided financial statements, designated to support the startup and operation of all of the applicant’s applied-for gTLDs.“

If no, please explain

Section “1.4.1.1. Challenge Mechanisms for CPE“ lacks a reference to applicable fees. At the end of the paragraph we recommend to add "There are no fees associated if an applicant files an Evaluation Challenge proceeding."