RDAP Implementation Comment Submission by Key-Systems GmbH

[Volker Greimann <vgreimann@xxxxxxxxxxxxxxx>]

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
www.domaindiscount24.com / www.BrandShelter.com

Follow us on Twitter or join our fan community on Facebook and stay updated:
www.facebook.com/KeySystems
www.twitter.com/key_systems

CEO: Alexander Siffrin
Registration No.: HR B 18835 - Saarbruecken
V.A.T. ID.: DE211006534

Member of the KEYDRIVE GROUP
www.keydrive.lu

This e-mail and its attachments is intended only for the person to whom it is 
addressed. Furthermore it is not permitted to publish any content of this 
email. You must not use, disclose, copy, print or rely on this e-mail. If an 
addressing or transmission error has misdirected this e-mail, kindly notify the 
author by replying to this e-mail or contacting us by telephone.