We posted our comments on the latest draft of the Applicant Guidebook for new gTLDs yesterday.

They can be read here.  For those who don't have time to go to the ICANN website to read them, here's an excerpt giving the general gist of what we said:

"We feel the forced exclusion of ICANN-accredited registrars from the new gTLD program is unfounded, detrimental to consumer and applicant choice and would lead incumbents in the registry market to enjoy unfair protectionism. It must not be implemented in the Final Guidebook."