Tucows appreciates ICANN Org for their work in drafting this Alignment Analysis and welcomes the Analysis’ confirmation that policy must be developed through the ICANN multistakeholder process before it can be applicable to Contracted Parties. Tucows notes with significant concern that implementation of a cost-recovery process funded by billing requestors for their use of the RDRS is barely considered in the Analysis, but supports the Analysis' conclusion that other aspects under consideration, including law enforcement authentication, mandatory use of the RDRS, and disclosure of Privacy Service or Proxy Registrant Data all raise significant and complex operational and policy questions which also can only be addressed through policy development work. Tucows does not support adding ccTLDs to the RDRS, as introducing unenforceable requirements causes significant confusion and complexity that is not well balanced by the potential benefit to requestors of being able to submit ccTLD requests through the RDRS.