Verisign comments on Thick Whois Consensus Policy Requiring Consistent Labeling and Display of RDDS (Whois) output for All gTLDs.

["Anderson, Marc" <mcanderson@xxxxxxxxxxxx>]

RE: Thick Whois Consensus Policy Requiring Consistent Labeling and Display of 
RDDS (Whois) output for All gTLDs.

https://www.icann.org/public-comments/rdds-labeling-display-2016-10-21-en

12 December 2016

Verisign appreciates the opportunity to comment on the proposed revised 
Registry Registration Data Directory Services Consistent Labeling and Display 
Policy ("CL&D Policy").  We would like to thank ICANN staff and the Policy 
Implementation Review Team ("IRT") for the time and effort that was expended in 
the creation of the proposed revised CL&D Policy.

Verisign is generally supportive of the proposed revised CL&D Policy; however 
we do offer the following feedback for consideration by ICANN staff and the IRT.

The revised proposed CL&D Policy currently stipulates an effective date of 1 
August 2017 and a "not to be deployed before" date of 1 November 2016.  As 1 
November 2016 has passed, this language is extraneous and can be removed.  In 
addition, the revised proposed CL&D Policy does not provide for any flexibility 
for ICANN to extend or modify the 1 August 2017 effective date for any reason.  
It is possible for legitimate issues to arise during the implementation of the 
CL&D Policy (include security and stability concerns) which may impact the 
ability of Registry Operators to comply with the 1 August 2017 effective date.

Verisign recommends that the revised proposed CL&D Policy include provisions 
for ICANN staff to provide extensions to the 1 August 2017 date in appropriate 
circumstances, in particular if legitimate security or stability concerns arise 
or in cases where a Registry Operator is operating in good faith to meet the 1 
August 2017 date but is unable to complete the necessary implementation 
requirements before that date.

We thank ICANN staff and the IRT for their consideration of these 
recommendations.

Marc Anderson
Verisign