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.meet Public Comment (Charleston Road Registry Inc. Request 03 September 2015 [PDF, 18 KB])

  • To: "comments-meet-proposed-amendment-22oct15@xxxxxxxxx" <comments-meet-proposed-amendment-22oct15@xxxxxxxxx>
  • Subject: .meet Public Comment (Charleston Road Registry Inc. Request 03 September 2015 [PDF, 18 KB])
  • From: Reg Levy <reg@xxxxxxxxxxxxxxxxxxxx>
  • Date: Thu, 3 Dec 2015 22:57:38 +0000

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

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