[bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working Group for Directory Services ( new Whois)

Smith, Bill bill.smith at paypal-inc.com
Mon Aug 5 16:12:52 UTC 2013


Attached is a marked up version of the document. I have attempted to replace web and website with Internet and service (generally) and hope that my changes read properly. I believe it important to make the distinction between the web and Internet since the ARDS is used for much more than the web.

I also included some comments and additions that I believe are necessary to include. In particular, I disagree with the assertion that there is no foundation for the belief that the scale of the ARDS make it vulnerable. Internet entities are vulnerable regardless of size but as they grow, they become increasingly attractive targets. ARDS will be attractive - or the Registrar community has been disingenuous about the scale of SPAM, customer loss, etc. that results from harvesting information via WHOIS.

I have also added text related to Gated Access and concerns related to data aggregation and operation of such a critical resource necessarily dependent on PII of security professionals. These individuals face very real risks given the work they do, those they "oppose", and the penalties imposed for crimes they uncover.

I hope we will consider the changes I have proposed.

On Aug 3, 2013, at 3:51 PM, stephvg at gmail.com<mailto:stephvg at gmail.com> wrote:

Thank you Steve, Laura, Susan, J Scott and Elisa for a well drafted document that I believe is perfectly inline with business users interests as defined by our charter.

If I might make a suggestion, even though it's out of scope of the EWG's work, I would love to see something in our opening comments about the fact that if the RDS model is adopted (or another unified model for managing gTLD registration data), it would be extremely beneficial for Internet users worldwide if ccTLD registries were also willing to work towards the adoption of the same, single-format, model.

I think it's useful for commentors to the EWG's draft report to make this point, even though ccTLD managers abide by their own national laws and ways of doing things, because we all have a lot to gain from a more effective and more uniform registration data database.

Apart from that suggestion, I have no other comments. The draft seems spot on to me and is supported by SVG Consulting Ltd.


Stéphane Van Gelder
Chairman and Managing Director/Fondateur

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Le 3 août 2013 à 17:53, Steve DelBianco <sdelbianco at netchoice.org<mailto:sdelbianco at netchoice.org>> a écrit :

It's time for the BC to comment on the draft model for Next Generation gTLD Directory Services.

The Expert Working Group (EWG) published its draft report here<https://www.icann.org/en/groups/other/gtld-directory-services/initial-report-24jun13-en.pdf>.

Public comment page is <http://www.icann.org/en/news/public-comment/atrt2-02apr13-en.htm> <http://www.icann.org/en/news/public-comment/thick-whois-initial-21jun13-en.htm> here<http://www.icann.org/en/groups/other/gtld-directory-services/share-24jun13-en.htm> and the EWG Wiki page is here<https://community.icann.org/display/WG/Explore+the+Draft+Next+Generation+gTLD+Directory+Services+Model>.

Laura Covington prepared the attached draft of BC comments, with help from Susan Kawaguchi, J Scott Evans, and Elisa Cooper.

The comment period closes 12-Aug-2013, so please Reply All before 11-Aug with edits or questions.

Steve DelBianco
Vice chair for policy coordination
Business Constituency

<BC Comments - EWG Draft Model [v1].doc>

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