The IPC’s position reflects a balance between three equally important imperatives among IPC membership. While it is important respecting the integrity of ICANN's policy development process there is a legitimate need for a CPE framework that is genuinely robust and resistant to abuse - which may be questioned under the current CPE framework laid out in the AGB and specified by the Draft subject to this comment.

The IPC recognises that CPE, when properly developed and applied, serves a valuable purpose in protecting the interests of genuine, established communities and ensuring that the new round of gTLDs delivers meaningful benefits to those communities it was also designed to protect. However, this value largely depends on how well the criteria for CPE are defined and how they are applied by the expert panel. A CPE framework that can be exploited by loosely organised groups or bad actors is not merely ineffective — it is counterproductive and risks discrediting the new gTLD program as much as it endangers the communities that it serves to protect.

The IPC therefore calls upon ICANN to ensure that the Draft review addresses the concerns raised in this comment, in particular, with respect to the interpretation of community identity under Criterion 1, the absence of any reference to the Specification 12 pre-condition, and the risk posed by the current scoring system's failure to distinguish meaningfully between strong and marginal community applications.

The IPC stands ready to engage constructively with ICANN and other stakeholder groups in refining the evaluation guide and remains committed to a New gTLD Program that is fair, transparent and credible all participants, including for applicants of dotbrand (.brand) domains and for applicants of community applications.