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Re: [gnso-thickwhois-dt] Comments on the Thick Whois PDP Draft Charter

  • To: "Drazek, Keith" <kdrazek@xxxxxxxxxxxx>, "Gnso-thickwhois-dt@xxxxxxxxx" <Gnso-thickwhois-dt@xxxxxxxxx>
  • Subject: Re: [gnso-thickwhois-dt] Comments on the Thick Whois PDP Draft Charter
  • From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
  • Date: Wed, 12 Sep 2012 00:22:51 -0400

Keith, regarding your first point - I would really like to understand to what extent the use of thick Whois by those registries that currently use is is or would be considered inconsistent.

I guess another way as asking the same question is what kind of inconsistencies are we ruling out by the need to be consistent?

By the way, despite my imprudent words the other day, this PDP really is about more than any registries that currently are running thin Whois. Although there are contractual terms for the current thick Whois registries and in the prototype agreement for new gTLDs, it is not currently a Policy. Therefore, there is nothing in theory stopping an existing registry or a new one from requesting/receiving an exception and implementing a thin Whois. Perhaps the current Board might not allow such a change, but there is nothing that forbids it. The outcome of this PDP (with or without "consistent") could remove that discretion in the future, so it is far wider than just one registry operator.


At 11/09/2012 07:10 PM, Drazek, Keith wrote:
Hi everyone,

Thanks to Marika for the great work kicking off the draft charter.

A few suggested edits:

1. I recommend amending the introductory sentence in Section 2, Mission & Scope from, “The PDP Working Group is tasked to provide the GNSO Council with a recommendation(s) on whether there should be a requirement for ‘thick’ Whois for all gTLD Registries” to “The PDP Working Group is tasked to provide the GNSO Council with a recommendation(s) on the consistent use of ‘thick’ Whois by all gTLD Registries.” The original wording appears to be focused on com and net only, where “the consistent use of thick Whois for all gTLD registries” allows for any future developments or modifications affecting all implementers of thick Whois and ensures that users of thick Whois can rely on a standard or consistent experience. In other words, just requiring the use of ‘thick Whois’ is insufficient; the WG should be making a recommendation concerning the consistent use of thick Whois among all registry operators. This also ensures the PDP WG’s eventual policy recommendation addresses the consistent use of thick Whois for all registries as a whole, and does not inappropriately single out one registry operator. Note that “consistent use” doesn’t preclude variations in the model as required by sponsored TLDs, etc.

2. The list of bulleted items looks very comprehensive, but I recommend the Drafting Team spend some time adding specificity to the list. The more specific we are in the charter, the better off we’ll be in determining whether the WG is successful in adequately addressing the issues, and knowing when each item is completed. I suggest that at least a sentence be added to each item in the list to provide a fuller explanation to make the charter clearer. Ideally, it would be helpful for each item to also have a list of questions to be answered; this would provide a more precise guide for the work to be done and would make it easier to measure completion. The list itself is good, but each bullet should be expanded upon.

Here’s an example:

For the bullet: “Impact on privacy and data protection, including consideration of possible cross border transfers of registrant data” it will be important that the WG answer questions like these: · Would registries and/or registrars be required to obtain consents from new and existing registrants before processing transfers? · Would registries and/or registrars be required to abide by different privacy and data protection laws in different jurisdictions? · How substantial are the compliance issues for registries and/or registrars with regard to varying privacy and data protection laws? Note that these questions are applicable to both existing registries and new registries because all registries will have to deal with transfers of domains and transfers of data”

I look forward to discussing further on Thursday and welcome any comments.

Thanks and regards,


Keith Drazek
Director of Policy

m: +1-571-377-9182
21345 Ridgetop Circle Dulles, VA 20166


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