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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

Name: Zoe Bonython
Date: 21 Nov 2022
Affiliation: RrSG
Please provide your feedback:
Section 1 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 2 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 3 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 4 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 5 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

The RrSG notes that ICANN has been negotiating a DPA with the contracted parties for several years. The RrSG encourages ICANN to complete these negotiations and to sign the respective DPAs with registrars and registries. Additionally, the RrSG notes that the wording in this section is ambiguous. The recommendation does not specify who can request a DPA, so theoretically a third party can require their own DPA. The recommendation should be clarified to ensure that registrars are not required to negotiate and/or sign substantial DPAs relating to their ICANN accreditation. If it is anticipated that there may be additional DPAs with third parties, then the RrSG recommends that the contracted parties create a standard DPA that can be used.

Please provide your feedback:
Section 6 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

The RrSG notes that recommendation 6.3 applies only at the time of registration, and suggests that to ensure PII is not inadvertently disclosed publicly, that these requirements also apply when technical contact information is updated. The RrSG is also concerned that registrars may not have a direct relationship with the technical contact, and may not be able to properly obtain consent to display PII. The IRT should resolve this ambiguity.

Please provide your feedback:
Section 7 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

The RrSG notes that while recommendation 7.2 refers to “Registrar Whois Server”, concurrently the RA and RAA are being amended to primarily replace whois obligations with RDAP requirements. While registrars may continue to provide whois service after the transition from whois to RDAP, the recommendations should include a reference to this change to avoid future ambiguity.

Please provide your feedback:
Section 8 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 9 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 10 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 11 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 12 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Addendum I accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Addendum II accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Implementation Notes accurately reflect the policy recommendations with no issues.
Please provide your feedback:
Background Section accurately reflects the policy recommendations with no issues.
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the AWIP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the ERRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Protection of IGO and INGO Identifiers in all gTLDs Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the CL&D Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the RNAP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Revised ICANN Procedure for Handling Whois Conflicts with Privacy Law correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Thick Whois Transition Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer FOA Confirmation correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer FOA Initial Authorization correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the TDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the UDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the UDRP Rules correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Procedure correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Rules correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Requirements correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the WDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Whois Marketing Restriction Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed Advisory Clarifications to the Registry and Registrar Requirements for Whois Data Directory Services correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed the RDAP Technical Implementation Guide correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed RDAP Response Profile correct?
Yes
Summary of Submission

The Registrar Stakeholder Group (RrSG) is pleased to comment on the Registration Data Consensus Policy for gTLDs and thanks the IRT team for their efforts. In general, it is the RrSG’s position that the policies accurately reflects the policy recommendations, with some suggested clarifications.  The RrSG also notes that the questions in regards to transfers are under review by the PDP Transfer Policy Review PDP.