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.
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The Coalition for Online Accountability (COA) appreciates the opportunity to comment on the Registration Data Request Service (RDRS) Policy Alignment Analysis paper (30 Oct 2025). COA participates in the ICANN process primarily through its membership in the IPC and fully supports the IPC’s comments with regards to this RDRS Alignment Analysis. However, COA would like to address specific areas with regards to the RDRS that are of particular concern to our membership,
This submission is in lieu of completing the Public Comment Proceeding Form. Summary is included in the Summary of Submission section below.
The Coalition for Online Accountability (COA) appreciates the opportunity to comment on the Registration Data Request Service (RDRS) Policy Alignment Analysis and wishes to express several serious concerns about the current operation of the RDRS.
COA’s mission is to promote online transparency and accountability by ensuring that WHOIS and related registration data remain accessible, accurate, and reliable for intellectual property rightsholders and other legitimate requestors combating copyright infringement, trademark abuse, phishing, and other online harms. While COA welcomes ICANN’s efforts to identify and address gaps in the RDRS, the current, largely voluntary framework is not meeting the needs of law enforcement or IP owners. In particular, COA is concerned that registrar participation in RDRS remains optional, timelines for responses are frequently ignored, decisions lack transparency, and the system is not sufficiently streamlined or user-friendly.
COA urges ICANN to move toward mandatory registrar participation in RDRS so that a centralized request mechanism is truly effective and worth using. Timelines for responses must be respected, with stronger oversight, tracking of overdue requests, and meaningful service levels for urgent matters. Registrars should also be required to give clear, specific reasons for denials, subject to ICANN oversight, to ensure consistency and accountability. COA further encourages implementation of an “Authorized Requestor” framework for vetted entities and the rapid deployment of APIs and other technical improvements to integrate RDRS into existing workflows. Collectively, COA believes these changes are essential for RDRS to deliver timely, predictable, and transparent access to non-public registration data in the public interest.