Name: Joyce Zheng
Organization: Alibaba Cloud Computing Ltd.
Submission ID: 159

Dear Sir or Madam,

Attached is our public comment form for IANA Stewardship Transition Proposal.

Best,Joyce Zheng
Sr.Project Manager
DBU-new gTLDs Alibaba-Elegant Leader Limited

URL: https://comments.ianacg.org/form
IANA Stewardship Transition Proposal - Public Comments Form
Disclaimer: In addition to the analysis of public comments, ICG will not use the collected information for any otherpurpose. Submitters' names, affiliations, and comments will be published.

Identification Information* Required Fields

Given Name * JoyceLast Name * Zheng
Email *REDACTEDCountry / Economy Organization / Institution: Alibaba Cloud Computing Ltd.

Questions Concerning the Proposal as a Whole1) Completeness and clarity: Is the integrated proposal complete? Each proposal submitted by theoperational communities includes aspects that need to be done in the implementation phases inthe future. Does the integrated proposal provide sufficient details that can be assessed against
the criteria put forward by NTIA?
We believe that the integrated proposal is complete, but some details still need modifications.
Especially, the composition and mechanism of CSC are not clear; how to truly protect theinterests of the top-level domain registries and registrars; and what are the specific measures toensure balance and fairness among different regions.
Also, some aspects, such as how does PTI work and how to constraint, etc. are not specified.

2) Compatibility and interoperability: Do the operational community proposals work together in an
integrated proposal? Do they suggest any incompatible arrangements where compatibility
appears to be required? Is the handling of any conflicting overlaps between the functions
resolved in a workable manner?

3) Accountability: Do the operational community proposals together include appropriate and properly
supported independent accountability mechanisms for running the IANA functions? Are there any
gaps in overall accountability under the integrated proposal?
We believe that the details of the accountability are still not clear enough, as the new community
mechanism lacks of details, and the specifics of how it works are not reflected, including how toallocate these 29 votes, i.e. whether geographical equity can be reflected. More detailed
discussions are needed, as well as its legitimacy.

4) Workability: Do the results of any tests or evaluations of workability that were included in theoperational community proposals conflict with each other or raise possible concerns when
considered in combination?

Questions Concerning the Criteria Put Forward by NTIA
5) Do you believe that this proposal supports and enhances the multi-stakeholder model? If yes,please explain the reasons. If not, please explain the reasons, and indicate what specificchanges you think should be made to the proposal.
Yes. The entire process is discussed and adopted in an open and transparent manner.

6) Do you believe that this proposal maintains the security, stability and resiliency of the DNS? If yes,please explain the reasons. If not, please explain the reasons, and indicate what specific changes
you think should be made to the proposal.

7) Do you believe that this proposal meets the needs and expectations of the global customers andpartners of the IANA services? If yes, please explain the reasons. If not, please explain thereasons, and indicate what specific changes you think should be made to the proposal. If you
are a customer or a partner of the IANA services, please indicate your identification.

8) Do you believe that this proposal maintains the openness of the Internet? If yes, please explain thereasons. If not, please explain the reasons, and indicate what specific changes you think should bemade to the proposal.

9) Do you concerns that this proposal would replace the NTIA role with a government-led or an intergovernmental organization solution? If yes, please explain the reasons, and indicate whatspecific changes you think should be made to the proposal. If not, please explain the reasons.
We believe that PTI should not be subject to the law of the United States only. It will affect theinterests of other countries.

10) Do you believe that the implementation of this proposal will continue to uphold the criteria put
forward by NTIA in the future? If yes, please explain the reasons. If not, please explain the reasons,and indicate what specific changes you think should be made to the proposal.

Questions Concerning ICG Report and Executive Summary
11) Do you believe that the ICG Report and Executive Summary accurately reflect all the necessary
information of the integrated proposal? If not, please explain what specific changes you thinkshould be made to the proposal.

General Questions12) Would you like to give ICG some general comments about this proposal?