Blacknight Comments on RDAP

[Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>]

We appreciate the opportunity to be able to provide comments on RDAP.

Blacknight is an ICANN accredited registrar based in Ireland. We are not a 
large company with infinite resources, so we are deeply concerned by ICANN’s 
insistence on pushing forward with RDAP at this juncture.

As other comments have mentioned, ICANN accredited registrars are obliged to 
provide a WHOIS service for “thin” registries only.

However ALL of the “thin’ gTLD registries are expected to be transitioned to 
“thick” under previously agreed ICANN consensus policy.

It is therefore unreasonable to implement RDAP at this time and thus force 
registrars to develop and support RDAP for a limited period of time.

It is also worrying that RDAP is being treated as purely a technical issue, 
while it is clear that there are policy issues closely linked to it.

In order for RDAP to be “useful” its implementation needs to be done in 
conjunction and in line with the necessary policies that would allow for 
differentiated access and safeguards to respect registrant privacy. 

At a higher level the issues associated with RDAP are systemic of ICANN’s 
disjointed approach to WHOIS. 
There are currently multiple work streams that impact WHOIS, yet there is also 
considerable overlap and potential conflict between these diverse work streams. 
It would, therefore, make more sense for ICANN to put ALL whois work “on hold” 
while some level of impact study and better project management was put in 
place. As a contracted party we are happy to comply with our contractual 
obligations, however the operational and financial impact of technical and 
policy changes need to be taken into consideration. Expecting us, or any other 
registrar or registry, to invest thousands of Euro and hundreds of hours in a 
technical requirement that could either be rendered moot or changed 
dramatically based on other ongoing work is not reasonable. 

Regards

Michele


--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
http://www.blacknight.host/
http://blog.blacknight.com/
http://ceo.hosting/
Intl. +353 (0) 59  9183072
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