.meet Public Comment (Charleston Road Registry Inc. Request 03 September 2015 [PDF, 18 KB])
To whom it may concern: Minds + Machines Group Limited writes in response to the Registry Service Evaluation Process (RSEP) request by Charleston Road Registry Inc. d/b/a Google Registry (“Google Registry”) to remove the requirement to operate searchable whois from Exhibit A of the .meet Registry Agreement. The New gTLD Applicant Guidebook (Guidebook) does not require registries to operate a searchable whois service, nor does any consensus policy exist regarding the operation of a searchable whois service. It would be inequitable and inconsistent with existing policies and requirements for ICANN to prevent subsequent removal of this service by way of the RSEP process. One of the purposes of the RSEP is to allow evaluation of the security, stability, or competition implications of new registry services. The operation of non-searchable whois service is not a new service, as several registries from the 2012 New gTLD Application Round already offer non-searchable whois services, with no evidence of accompanying issues or community concerns. Nor is this a new service for the registry operator, as Google Registry also operates 43 new gTLDs including .how, .soy, and .みんな, which have been commercially launched to date and do not use searchable whois. Not only would the operation of a comparable, non-searchable whois service not raise new issues that would justify ICANN’s non-approval of an RSEP request, comments to this effect are inappropriate. According to the posted comment, ICANN has undertaken a preliminary determination on whether the proposal might raise significant competition, security or stability issues. ICANN's preliminary review (based on the information provided) did not identify any such issues for this proposal. (Emphasis added.) The fact that it has been posted for public comment in the first place must be a mistake, as the posted Registry Services Workflow clearly indicates that, if ICANN does not find any security, stability, or competition issues—which, as noted above, it did not—the matter would proceed immediately to implementation and the Amendment neither sets new precedent (as noted above, many registries operate non-searchable whois services) nor does it have substantial effect on any party (ICANN, the DNS, or anyone else). Minds + Machines Group Limited urges ICANN to not bar RSEP requests that refer to optional registry services. The other major purpose of the RSEP is to provide consistency for registry operators. Since this proposed registry service does not raise significant competition, security or stability issues and does not affect any other party, the publishing of this Amendment for public comment is unexpected for both Google Registry and the community. Minds + Machines Group Limited is fully in support of the ability of a registry operator to add or subject routine—and especially routine and optional—services without a public comment period. Minds + Machines Group Limited nevertheless supports Google Registry’s removal of searchable whois from .meet and the contract amendment as posted. Sincerely, Reg Levy + + + Reg Levy VP Compliance + Policy Minds + Machines m +1 310 963 7135 w +1 310 730 4104 Current UTC offset: -7 Attachment:
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