The gTLD Registries Stakeholder Group (RySG) appreciates the opportunity to provide feedback to the GNSO on the Findings Report of the RDRS Standing Committee. The RySG notes that the RDRS pilot represents an innovative approach to gathering data to help inform policy. Such an effort wouldn’t be possible without the hard work of ICANN org and the broader community. The RySG would like to further express our appreciation for everyone involved in the RDRS pilot. 

The RySG is generally supportive of the report and the recommendations contained within. We offer the following comments.

1) Recommendation #3.

The RySG is supportive of the three proposed RDRS enhancements in Recommendation 3; however we believe a fourth should be included. To provide a link from the RDRS to disclosure request information (or systems where applicable) for non-participating registrars as listed in the table under “proposed future enhancements”. This is a relatively small enhancement that would greatly improve the requestor user experience. 

2) Recommendation #4

a. Recommendation 4.1 suggests the GNSO Council consider further policy work around privacy/proxy data, however it is very ambiguous as to what that policy work should entail. The RySG suggests the standing committee revisit this recommendation and clarify what further policy work it is recommending the GNSO Council undertake and what the desired outcome(s) are.

b. Recommendation 4.2 suggests policy to require links in RDAP responses to the RDRS (or its successor). The RySG doesn’t support this recommendation. From a technology perspective it doesn’t make sense. RDAP separates the delivery of domain registration data (which links to RDRS are not) from the display of that data. An RDAP client (like lookup.icann.org) is the appropriate place to put the link where it can be displayed in human readable format (rather than buried in an RDAP response). The RySG notes that lookup.icann.org was updated to include a link to the RDRS as part of the pilot.

3) Recommendation #5. 

SSAD #17. The standing committee recommends keeping SSAD recommendation #17 without changes. The RySG notes that the reporting providing during the RDRS pilot period differs from what is specified in SSAD Rec #17. The RDRS reporting has been helpful and well received. The RySG suggests the standing committee revisit its recommendation to keep #17 unchanged and consider if “modify” might be appropriate given the learnings from the RDRS pilot.

The RySG is generally supportive of the report and the recommendations contained within, and offers additional comment on Recommendation #3, Recommendation #4, and Recommendation #5.