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RDAP Implementation Comment Submission by Key-Systems GmbH

  • To: comments-rdap-profile-03dec15@xxxxxxxxx
  • Subject: RDAP Implementation Comment Submission by Key-Systems GmbH
  • From: Volker Greimann <vgreimann@xxxxxxxxxxxxxxx>
  • Date: Fri, 18 Mar 2016 11:11:17 +0100

To Whom it may concern,

Key-Systems GmbH appreciates the opportunity provided by ICANN to comment on the RDAP Operational Profile for gTLD Registries and Registrars.

Key-Systems GmbH supports the alternative framework proposed by Google Inc. in its comments on Thick Whois/RDAP Implementation <http://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfXEuYViKmu4.pdf>. We further support the comments of the RySG <https://forum.icann.org/lists/comments-rdap-profile-03dec15/pdfssl7te1KLl.pdf> as well as the forthcoming comments of the Registrar Stakeholder Group.

Key-Systems GmbH firmly opposes any implementation without significant benefit, i.e. implementation of new protocols that will not be a significant improvement over currently existing systems, in this case port 43 whois unless the policy work on how to implement the additional features with regard to authenticated access and differential output is complete.

Key-Systems GmbH also fimly opposes any implementation that will be rendered obsolete within the forseeable future. As GNSO policy recommendations to replace thin whois with thick whois in all gTLDs have been accepted by the ICANN Board and are currently in the implementation path, any implementation of a replacement protocol such as RDAP on the side of the registrars would provide zero benefit to internet users but result in significant implementation and opportunity costs on the side of registrars. This implementation may further be rendered obsolete by the ongoing policy work on the Replacement Data Protocol based on the work of the EWG on gTLD Directory Services.

Section 3 of the Operational Profile describes implementation requirements for registrars. The requirements for registrar implementation should be consistent with the 2013 Registrar Accreditation Agreement. This implementation requirement will require registrars to commit significant resources to develop, deploy, and operate a software service that will ultimately end up being discarded very shortly afterward once all gTLD registries provide thick services themselves. This is not a commercially reasonable requirement.


Should you have any further questions, please do not hesitate to contact us.

Best regards,

Volker A. Greimann
- legal department -

Key-Systems GmbH
Im Oberen Werk 1
66386 St. Ingbert
Tel.: +49 (0) 6894 - 9396 901
Fax.: +49 (0) 6894 - 9396 851
Email: vgreimann@xxxxxxxxxxxxxxx

Web: www.key-systems.net / www.RRPproxy.net
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