Comments from Key-Systems GmbH
Dear Sir / Madam I am submitting these comments in my capacity as General Counsel of Key-Systems GmbH, an ICANN accredited registrar based in Germany. Firstly I would like to thank the members of the Working Group for their efforts to tackle this matter. Volunteer work is at the core of ICANN's activities and should be recognized and appreciated. Key-Systems supports the comments made by the RrSG, and offers the following additional considerations: Charter Question 1: We respectfully suggest that there should be no requirement to translate or transliterate contact information to a single common language or script. Instead, registrants should be able to input their data in the language or script most applicable to them, provided such script is supported by the sponsoring registrar. Contactability of the registered name holder is always guaranteed by the presence of the email address data. Charter Question 2: We respectfully suggest that the burden of accessing and understanding contact information is best placed on the side of the beneficiary of such data, i.e. the data requestor. As a requestor may itself use a different script or language from any common script or language mandated, a mandated translation or transliteration would only benefit the subgroup of potential requestors that share the common script or language with the mandated one. Consequently, all requestors who do not share that script or language may have to perform the translation or transliteration on their own anyway. Additionally, free translation services are available that fulfill the required purposes for requestors. Furthermore, transforming all records despite the fact that only a fraction thereof will ever be requested by a requestor would result in a significant cost-benefit imbalance. We therefore support preliminary recommendation #1. We do not support preliminary recommendation #3 as most registrars operate internationally. The language the registrar operates under may therefore not be appropriate to serve customers elsewhere. Such a recommendation would hinder competition between registrars and hinder free transferability of domain names. We further propose adding an additional tag to the contact data that identifies the script or language used for easier reference of the requestor as contemplated in PR #2 and PR #4 should be strictly optional as neither registrar nor registrant can be expected to know the tag applicable to any given set of data. Nonetheless, having the option to display available to registrars and registrants, such a tag may yield beneficial results for requestors. We agree with PR # 5 that any optionally provided transformation should only be presented in additional fields, preserving the originally entered data in the mandatory fields. -- 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.