Input to Expert Working Group on gTLD Directory Services EWG Status Report Questions from Chuck Gomes, 15 November 2013

[Gomes, Chuck]

Please note that the following questions and comments are submitted in my personal capacity.  They are organized chronologically under respective headings from the report

I will be in Buenos Aires and I plan to attend the EWG session with the GNSO on the weekend, but I have conflicting obligations during the general EWG sessions during the week, so I am sending my questions and comments in advance.  Feel free to address them in those sessions if you like.

I want to compliment the EWG for all the work you have done to date.  I found the work done since Durban to be outstanding.  The report is one of the cleanest I have seen but more importantly, I am very impressed with the way you responded to public input and also think that you are headed in a direction that holds lots of promise.

Principles for Data Collection, p.12

*         Under data collected by registries & registrars, 1.d is 'Registrant Type': "Indicates the kind of entity identified by Registrant Name: natural person, legal person, proxy service provider, trusted agent "  Is there intention to validate these in anyway and if so how, especially for natural v. legal person?

Data Disclosure Principles, pp. 13-14

*         4.e is Registrant Email Address.  Disclosing email for the registrant seems like it could be problematic.  What is your thinking in that regard?

Table of Resulting Data Classifications on pp. 16-17

*         I note that the collection of info for Reseller and Registrant State/Province are optional.  Are they optional because they are not be applicable in some cases or are they truly optional?  If the former, it seems to me that it would be good to clarify that.

*         Original registration date is also optional?  Why?

Data Definitions, p.18

*         For the Original Registration Date, does this mean for the existing registration or for any that may have occurred earlier that were deleted?  Might be good to clarify.

Additional Gated Access Principles, pp. 19-20

*         In item 4, one of the possible 4 ways for accreditation for access to data is self-accreditation.  In what cases would that be considered?  It seems like it could be easily abused.

*         Items 6 & 7 refer to RDS as an organization.  What is meant by that?  I thought RDS was a system.

Chart on p. 25

*         Are the Y & N in the flow chart decision box for steps 4 & 5 reversed?

Consideration of RDS Costs & Impacts, p. 55

*         It seems to me that many of the costs in today's system are distributed across the community rather than being concentrated in any one entity; don't you think that the RDS will require significant funding to develop and operate?

Cost Principles, p.56

*         Principle 5 says: "A common software platform should be developed and funded by ICANN, to minimize the implementation costs on registrars/registries."  If and when it is decided to implement the RDS, maybe costs like these could be funded by new gTLD auction funds if there are any.

Investigation of Applicable Risk/Impact Analysis Frameworks, p. 57

*         The last paragraph on p. 57 talks about a risk/impact analysis for the Disclosure Control Framework.  Is this something the EWG plans to do and will that be done before the EWG finalizes its recommendations?


Cost Impacts of Implementing Possible RDS Models, p. 59

*         I am sure the EWG realizes that ongoing costs need to be considered as well as upfront costs to implement the RDS.

Lower Costs of Implementation, p. 82

*         "Here, a model that with lower cost of implementation overall is considered stronger."  I am not sure that this is a true assumption if long-term costs are less.

Thanks in advance,

Chuck Gomes
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