Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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While ".INTERNAL" is "relatively short", it's still a fairly long domain suffix.
Given the fact that this suffix will likely to be used in multilevel private domain/hostnames, which itself can be quite long (for exaggerated examples, "service1.department1.gateway1.company.routing-software.internal" and "aWt8RCs5TFRYIVQjImt1OWUhQk51cVhEUyVm.ipfs.internal"), it could be beneficial to shorten it's every possible element, including the TLD.
So, maybe consider to further contract the suffix to ".I", which is friendlier for application integration, and is not conflicting with most current usages in the field.