[Gnso-impl-thickwhois-rt] Registrars have to inform affected Registrants?

[Tobias Sattler]

Hi there,

Just a follow up on our call today. Did I get the right, as a registrar we have to inform all affected registrant via email that we are
moving from thin to thick 30 days before the transition?

If so, I strongly oppose that. The thing is that in registrants have to confirm the terms and conditions in the first place, where they
acknowledge that their contact information will be made available through Whois and if it applies through a 3rd party like a registry.
Furthermore they agree to the term that we have to escrow them. Most of the registrars are using Iron Mountain for that.

With the new RRA 2013, as a registrar, we have to escrow the underlying contact information in case of a Privacy Proxy service
managed by the registrar. In case were the customer has ordered an own service we do not have this data and we would be able
to make sure that we actually reached out to the registrant.

Furthermore if we are just talking about .com domain names for an instance, we would have about 317,000. If we would reach out
the registrants, we will definitely be hit by an enormous amount of phone calls, because most our registrants do not know the difference
between Thin and Thick Whois nor would they care. At the end of the day, this transition won’t affect the registrants.

If this group needs more feedback then I would suggest to reach out to the Registrar Stakeholder Group.

In my personal opinion, if we really have to do this outreach, I would rather like to change this obligation to something like that:
"In case the contractual relationship between the Registrar and Registrant or local legislation does require to inform the Registrant
about such transition the Registrar shall inform the Registrant 30 days before the transition."

Best regards,
Tobias