Input to Expert Working Group on gTLD Directory Services a response from JPNIC

[MAEMURA Akinori]

I hereby submit our response for the Draft Next Generation gTLD 
Directory Services Model.

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We appreciate the Expert Working Group for all the effort it has taken
in developing the Initial Report, especially crafting the proposed 
ARDS model, from the thorough analysis of the users and purposes.



We, Japan Network Information Center (JPNIC) would like to share our
observation about the ARDS model, based on our experience as a National
Internet Registry (NIR) in Japan that operates our own WHOIS for IP
address.

We found the proposed model would be able to solve many problems 
identified, and agree the many advantages which are listed in 5.1 .  
while we also agree on the disadvanges there.


This response is for us to raise two concerns on the proposed model.  
One of them is about 'Crieation of "Big Data" source', which is raised 
in the disadvantage.  The other is about the restriction of the 
jurisdictions of the countries where the gTLD registries located.


The creation of "Big Data" Source:  The proposed model collects and
concentrates the copy of the registry data from all gTLD registries.
It will result in that the ARDS holds the exhaustive data on gTLD
registration, which will benefit not only in the users with good wills,
but also "misreants" who attempt abuse on the data.  As it would be
the most ever exhaustive, it will require the best ever security
practice.  The various security concern must not be contempted.

Our consideration has found one possible solution to address this risk.
In our observation, major purposes of the proposed model are to single
point of data requests and to concentrate the function of authentication
of the users for privilleged information.  With them concentrated at
ARDS, some technical solution can be developed to send requests to the
registries to have them send the data which was requested and authorised
directly to the requestors.

The restriction of the jurisdictions of the countries where the gTLD 
registries located: The proposed model assumes that all gTLD registries
provide the registry data to the ARDS.  However, some national laws 
may prohibit or make it difficult for registry operators in the country
to provide some of information, especially those related to privacy of 
the registrants, to the third party,  especially to those abroad.  In 
the case, it may be impossible to realize some part of the model as 
proposed.  This point should be carefully considered.

We have a reference of the practice which may address this problem.  
For the IP address management in Asia Pacific Region, we have National 
Internet Registries, NIRs, which serve the concerned country or economy 
under APNIC.  The registry data is fundamentally collected and stored 
in the NIR, then mirrored to APNIC.  Here, All the data is not neccesarily 
mirrored to APNIC but a part of them, taking into consideration each 
NIR's restriction.  Moreover, when a user access APNIC whois for a 
record from a NIR, the field of the data which is not mirrored to APNIC
in the record is shown "refer NIR whois: URL..." to encourage the user 
to refer the NIR's whois.

With these inputs, we admire and appreciate very much the outcome which 
EWG has achieved until now, and do hope the forthcoming works, including
the integrating the inputs and consideration of the remained items, will
be very fruitful.
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MAEMURA Akinori   General Manager, Internet Development Dept.
maem at nic.ad.jp      JPNIC - Japan Network Information Center