The RrSG appreciates the work of ICANN Org in rafting this Analysis. The RrSG agrees with the Analysis that many of the potential outcomes considered do require further Policy work, specifically including the authentication of law enforcement users, a mandatory requirement to use the RDRS, and treatment of domains using a registrar's Affiliated Privacy service.

The RrSG is significantly concerned about the lack of consideration given to billing for cost recovery in the Analysis; implementation of the recommended billing functionality is a crucial component of any long-term system and the RrSG urges the ICANN Board to confirm that if the RDRS or any other system is maintained long-term or made a mandatory system for registrars to use then the first piece of work will be to build out this necessary billing functionality.

Finally, the RrSG notes that enabling ccTLD participation while those ccTLD participants are not bound by the policy governing this system will result in unclear requirements and confusion for requestors and registrars; the RrSG does not support this proposal. A set of questions are noted in the Comment which must be considered by the appropriate group—and may require policy development work—before ccTLDs can be included in RDRS