It is important to note that the particular correspondence
that you are referring to is in relation to an earlier proposal entitled "Sunrise
Plus 20" and not sunrise periods in general. To the best of our knowledge, this proposal
was never ratified and has no bearing on this process.In it's current capacity,
Tucows is purely functioning as a provider of outsourced technical management functions
for a number of competitive ngTLD bids, and therefore, we find it inappropriate to
comment on any of the policy statements that the various sponsoring organizations
or registry operators propose.
We do however continue to stress the value of this
consultative, public process and fully support ICANN's efforts to ensure that all
affected stakeholders continue to have an effective mechanism by which they can equitably
participate in these and related proceedings.