[PC-NCSG] Public comment period RDAP

[Stephanie Perrin]

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 <avri at apc.org> 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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>
>
>
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