Hi,

In case anyone is confused right now, we are talking about two open public comment that are associated with each other. Folks seem to be addressing them interchangeably, but that is understandable because they have some common elements. Anyway…, these are the two topics under discussion:

1. Registration Data Access Protocol (RDAP) Operational Profile for gTLDRegistries and Registrars: https://www.icann.org/public-comments/rdap-profile-2015-12-03-en

2. Proposed Implementation of GNSO Thick Whois Consensus Policy Requiring Consistent Labeling and Display of RDDS (Whois) Output for All gTLDs: https://www.icann.org/public-comments/rdds-output-2015-12-03-en

I agree that the objections raised by the registries and registrars are all quite reasonable. It looks like staff are indeed making some policy decisions, or at a minimum are misinterpreting existing policy and designing an implementation framework based on those mistakes.

Several comments indicate agreement that staff is going beyond the scope of the “thick” whois consensus policy. I fully agree with that. There are some whois fields that are not mandatory in the 2013 RAA, that are for some reason mandatory now in this implementation framework. Those include registrar abuse contact info, a field for reseller info and the registrar expiration date. The “thick” whois PDP never made any recommendations to make those changes to the RAA.

Also…, “thick” whois never recommended replacing the current whois with RDAP. That would have been way beyond the scope of that PDP, and so also should be beyond the scope of the policy’s implementation framework. In the staff draft paper they say that this is a consensus policy coming out of “thick” whois:

> The implementation of an RDAP service in accordance with the "RDAP Operational Profile for gTLD Registries and Registrars" is required for all gTLD registries in order to achieve consistent labeling and display in the replacement for (port-43) WHOIS


I’m not sure where they got this from, but it wasn’t an output of the “thick” whois PDP.

I feel comfortable with reversing my original position, and recommending that we not endorse the IAB comment. If anything, I believe we should be endorsing the Google comment indicated by Kathy, and found here: https://forum.icann.org/lists/comments-rdap-profile-03dec15/msg00011.html

Thanks.

Amr

> On Mar 18, 2016, at 8:25 PM, Stephanie Perrin <[log in to unmask]> wrote:
> 
> Also a very sensible comment.  So we tell them to delay implementation until after WHO2?
> cheers Stephanie
> 
> On 2016-03-18 14:19, Kathy Kleiman wrote:
>> Hi All, 
>> I don't have time to incorporate, but agree with the trend of NCSG comments to support the Registrars (and Registries) in the concerns they are voicing about the RDAP implementation process now in play. Too many processes going on all at once... normally our argument! 
>> 
>> I share Google's comment (attached) and Volker's comment (below). Michele has also submitted comments. 
>> ------------ 
>> 
>> To Whom it may concern, 
>> 
>> Key-Systems GmbH appreciates the opportunity provided by ICANN to comment on the RDAP Operational Profile for gTLD Registries and Registrars. Key-Systems GmbH supports the alternative framework proposed by Google Inc. in its comments on Thick Whois/RDAP Implementation <http://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfXEuYViKmu4.pdf>. We further support the comments of the RySG <https://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfssl7te1KLl.pdf> as well as the forthcoming comments of the Registrar Stakeholder Group. Key-Systems GmbH firmly opposes any implementation without significant benefit, i.e. implementation of new protocols that will not be a significant improvement over currently existing systems, in this case port 43 whois unless the policy work on how to implement the additional features with regard to authenticated access and differential output is complete. Key-Systems GmbH also fimly opposes any implementation that will be rendered obsolete within the forseeable future. As GNSO policy recommendations to replace thin whois with thick whois in all gTLDs have been accepted by the ICANN Board and are currently in the implementation path, any implementation of a replacement protocol such as RDAP on the side of the registrars would provide zero benefit to internet users but result in significant implementation and opportunity costs on the side of registrars. This implementation may further be rendered obsolete by the ongoing policy work on the Replacement Data Protocol based on the work of the EWG on gTLD Directory Services. Section 3 of the Operational Profile describes implementation requirements for registrars. The requirements for registrar implementation should be consistent with the 2013 Registrar Accreditation Agreement. This implementation requirement will require registrars to commit significant resources to develop, deploy, and operate a software service that will ultimately end up being discarded very shortly afterward once all gTLD registries provide thick services themselves. This is not a commercially reasonable requirement. 
>> 
>> -- 
>> 
>> Should you have any further questions, please do not hesitate to contact us. 
>> 
>> Best regards, 
>> 
>> Volker A. Greimann 
>> - legal department - 
>> 
>> ------------------- 
>> Best, 
>> Kathy 
>> 
>> 
>> On 3/18/2016 11:18 AM, Amr Elsadr wrote: 
>> Hi, 
>> 
>> On Mar 18, 2016, at 3:32 PM, avri doria <[log in to unmask]> wrote: 
>> 
>> Hi, 
>> 
>> I also agree with the IAB position, and would be happy to see NCSG 
>> endorse that position. 
>> 
>> One consideration, though, is how it will affect your alliance with the 
>> RrSG.  Is this a capital expense they want there to be a commitment to. 
>> Would they agree?  While this is not a consideration for me, I do advise 
>> thinking that through.  Does not change my position, but those of you 
>> fighting in the trenches on the WG might want to think about that. 
>> That’s a very fair point. We are effectively endorsing the implementation of a system before a PDP that is just beginning is supposed to make a determination on whether or not it is necessary to use it at all. 
>> 
>> I expect that use of RDAP will be found to be necessary, but see how we are jumping the gun endorsing its use, even in the absence of any features that require other policy considerations 
>> 
>> Also, is this in scope for either the WG or even the GNSO?  And how 
>> would anyone force the Registrars to do it? 
>> I believe so. Why wouldn’t it be within the scope of the WG and GNSO? Am I missing something? 
>> 
>> And registrars can be forced to do it via changes in the RAA, right? I’m certain they will be all over any work that may lead to changes in their contractual obligations, so will hopefully be part of the discussion and final decision. I don’t imagine they are ever happy about spending money to implement ICANN policies, but suspect they’ve seen this coming for a while now. I may, of course, be delusional. 
>> 
>> Thanks. 
>> 
>> Amr 
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