[PC-NCSG] Public comment period RDAP

[Kathy Kleiman]

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  [1]. We further support the comments of the RySG  [2]
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  [3] 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 
_______________________________________________ 
PC-NCSG mailing list 
PC-NCSG at ipjustice.org [4] 
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Links:
------
[1]
http://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfXEuYViKmu4.pdf
[2]
https://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfssl7te1KLl.pdf
[3] mailto:avri at apc.org
[4] mailto:PC-NCSG at ipjustice.org
[5] http://mailman.ipjustice.org/listinfo/pc-ncsg

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