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