We would agree withthe comments submitted by Tim Switzer of DotGreen and echo those sentiments here.

[Richard Schreier <richard@xxxxxxxx>]

In response to the SSAC report on dotless TLDs, it would seem to be premature

and unnecessary  at this point to invoke an "across the board" ban on dotless

TLDs.  The New gTLD Guidebook, via the RSEP in the Registry Agreement, allows

individual registries to submit a specific request for a dotless TLD and in

this established process, the request would be thoroughly vetted for security

and stability issues by a panel of technical experts.  It would not be prudent

to make a change at this time to the New gTLD Guidebook and Registry Agreement

given the advanced stage of the New gTLD process.


Thank you for the opportunity to submit this comment.