Public Comment on 2013 RAA Data Retention Specification

[Tamer Rizk <trizk@xxxxxxxxxxxx>]

Instead of shifting the burden of data maintenance to registrars, ICANN 
may be better served by focusing on registrar compliance with data 
escrow agreements that are actually necessary to preempt future 
RegisterFly like events given the complexity of the gTLD environment, 
implementing systems to autonomously validate the integrity of the data, 
as has long been recommended by section eight of the Second WIPO 
Internet Domain Name Process, and working with legislative bodies within 
the context of proposed legislation, such as the GDRP, in order to 
safeguard the privacy of data that may facilitate processes such as UDRP.