[Gnso-ssr] discussion -- SAC061 -- SSAC Comment on ICANN's Initial Report from the Expert Working Group on gTLD Directory Services

Mon Feb 17 14:49:11 UTC 2014

Dear Mikey:

Regarding #1:  gTLD transfers have generally worked over the years because
all registrars have provided contact data via WHOIS.  There has been pain
because the data was not always uniform in format, and not all registrars
provide thick data via port 43, but generally the contact data was
obtainable and life went on.   IRTP helped and the 2013 RAA irons out format
issues.

Regarding #2: See above; transfers will muddle on in the meantime.  

I note that the Board asked that the EWG address key questions posed in
SAC055.  So when the EWG's final report comes out, it would be logical to
compare it to both SAC055 and SAC061.

All best,

--Greg

From: Mike O'Connor [mailto:mike at haven2.com] 
Sent: Sunday, February 16, 2014 7:35 PM
To: Greg Aaron
Cc: Stephanie Perrin; GNSO SSR List
Subject: Re: [Gnso-ssr] discussion -- SAC061 -- SSAC Comment on ICANN's
Initial Report from the Expert Working Group on gTLD Directory Services

hi Greg,

you raise a couple of interesting questions.

1) in the case of a thin registry, how does the gaining registrar do that
2013 RAA verification and validation?  it's my understanding that job is
easier if both registrars are under the 2013 RAA, because then they are both
obligated to provide uniform Whois display.  so a script could be written to
pull that data from the losing registrar and that script could count on
success.  but what if the losing registrar isn't a signatory to 2013 RAA
yet?  that looks like another in that pile of dependencies, no?

2) what about all the European registrars (like Michele) who <stirring up a
hornet's nest> haven't signed the 2013 RAA yet because of the conflict with
European privacy law?  yet another dependency, i bet.

OK.  what i've learned from this topic so far is;

- EWG still has substantial work to do, which certainly won't be finished by
Singapore - but maybe London

- we should wait to see how SAC061 advice is incorporated into that EWG
report before trying to decide what the next step is for the GNSO - so
again, maybe London

fair summary?  is there anything in SAC061 the GNSO should look at in
Singapore?

mikey

On Feb 16, 2014, at 3:30 PM, Greg Aaron <greg at illumintel.com> wrote:

The 2013 RAA says that when a domain is transferred between registrars, OR
when a domain is transferred between registrants, "both Whois information
and the corresponding customer account holder contact information related to
such Registered Name" must be verified and validated.  So it must happen
with inter-registrar AND inter-registrant transfers. 

http://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13
-en.htm#whois-accuracy 

Registrars who have signed the 2013 RAA sponsor most of the gTLD domains
that exist. 

The community must understand what the current policies are, see if proposed
new policies are superior, what the implications of any new proposals are,
etc.  If the EWG final report doesn't lay out all of that, then the GSNO
will have to make sure it's done, because it's tasked with making/approving
the policies that come out of the EWG work.  I suspect that there are
dependencies that have not been documented and discussed yet.   And I note
that the " central repository" of WHOIS policies is not complete.
http://whois.icann.org  

All best,

--Greg

From: gnso-ssr-bounces at icann.org [mailto:gnso-ssr-bounces at icann.org] On
Behalf Of Stephanie Perrin
Sent: Sunday, February 16, 2014 8:57 AM
To: Mike O'Connor
Cc: GNSO SSR List
Subject: Re: [Gnso-ssr] discussion -- SAC061 -- SSAC Comment on ICANN's
Initial Report from the Expert Working Group on gTLD Directory Services

Sorry forgot to answer your key question....as you pointed out in Buenos
Aires from the mike, some people are doing all the work in the working
groups.  Absent that connective tissue, I have not seen any other mechanism.
There is a lot of material to cover....hard to catch everything, if you are
just sitting around reading all the minutes and notices etc.  Transparency
is not enough....

cheers Stephanie

On 2014-02-16, at 8:42 AM, Stephanie Perrin wrote:

That does raise interesting questions.  First one I have, is do all
registrars get to look at all data, or do they only get to look at a
particular transaction?  I would hope the latter, because that would be
compliant with data protection law, if they get to look at all data that
would not, in my view, be compliant.  It would have been easy to engineer a
consent mechanism in there to get around this problem, which would be normal
in other commercial transactions, and would also perform a security
function.

The second question of course, remains begging in my view, with respect to
the EWG work.  How on earth are we going to accredit actors to look at the
ARDS?  Do all registrars get to look at all data all the time, if not how is
it going to be policed?  How many miscreant registrars are there out there?

AS always, pardon the naivete of my questions. 

Stephanie

On 2014-02-16, at 8:29 AM, Mike O'Connor wrote:

thanks Stephanie and Greg for kicking this thread off so well.

let me add another dimension to the discussion - i'm going to combine a
couple of fuzzy terms to coin a new one and see if it sticks.  "Policy
Architecture"   

i'm involved in several WG's that touch (or depend on) Whois, or its
replacement.  the most interesting puzzler is the IRTP-C PDP, which
introduced the notion of "inter REGISTRANT transfer" to the existing inter
REGISTRAR transfer policy.  IRTP-C is now in the implementation process and
there are turning out to be a lot of dependencies in there.  

one of the fundamental notions that IRTP-C introduced was the idea that
registrars need determine whether the transfer is just inter-registrar, or
whether it's also inter-registrant.  the question is, how will registrars
determine whether the registrant is changing or not?  one answer, which
works in thick Whois environments, is to go look at whois data at the
registry and see if registrant data is changing.  if it is, then it's an
inter-REGISTRANT transfer and new safeguards apply.  if not, it's just an
inter-registrar transfer.

when we wrote that section of the report, we knew that it was hard to do
that - but we were (correctly) counting on some things changing fairly soon.
sure enough, the Thick Whois PDP has just been approved by the Board, which
means that "go look at registry data" option will exist for all TLDs.  

the puzzler for me is who looks after these meta-level dependencies?  what
if Thick Whois had gone the other way?  what if the EWG process concludes
that registrars can't look at that data?  who minds that "architectural"
framework in the policy-making process?

mikey

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