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Summary of Public Comments

  • To: "raa-consultation@xxxxxxxxx" <raa-consultation@xxxxxxxxx>
  • Subject: Summary of Public Comments
  • From: Marc Salvatierra <marc.salvatierra@xxxxxxxxx>
  • Date: Thu, 9 Apr 2009 14:54:34 -0700

Submitted by ICANN Staff on behalf of Tim Cole


GNSO-approved set of RAA Amendments
Summary of Public Comments

The public comment period for the GNSO-Approved Amendments to the Registrar 
Accreditation Agreement was open from 6 March 2009 until 6 April 2009 pursuant 
to a Board resolution at the Mexico City meeting 

A total of five distinct submissions were received during the comment period 
and are summarized below.

GoDaddy.com, Inc.
This letter expressed support for the published amendments and acknowledged the 
"time, effort, and spirit of cooperation" by all of the GNSO constituencies in 
their development.

The letter also suggested that the ICANN Board of Directors consider financial 
incentives be used to encourage early adoption.  It also stressed that the 
amendments should be adopted as a group.

Deutsche Telekom AG
This comment focused on the Registrar Audit provision and, specifically, the 
terms under which Registrar confidential information can be made public.  
Concern was expressed that the term "Registrar confidential information" was 
not defined and that any disclosure "should respect national laws and 
especially data protection laws."  The comment requested that the term be 
better described and that publication of any confidential information respect 
all applicable laws.

Danny Younger
This comment focused on the implementation procedure, objecting to the extended 
time involved in waiting to implement the amendments until each RAA expires and 
renews.  The comment proposed following a provision in the RAA whereby the 
ICANN Board of Directors can adopt consensus policies on a temporary basis if 
it "determines that immediate temporary establishment of a specification or 
policy on the subject is necessary to maintain the operational stability of 
Registrar Services, Registry Services, the DNS, or the Internet, and that the 
proposed specification or policy is as narrowly tailored as feasible to achieve 
those objectives."

Internet Commerce Association
The letter submitted by the ICA urged swift approval by the ICANN Board of 
Directors of the proposed amendments and that the Board should explore 
incentives to encourage early adoption by registrars.  The ICA also expressed 
support for the process to establish a registrant rights charter as detailed in 
the GNSO motion.

Registrar Constituency
This comment expressed support for the published set of amendments and 
encouraged adoption by all registrars "sooner rather than later."  The 
constituency suggests that ICANN provide financial incentives for registrars to 
adopt early that could offset the additional compliance costs to be incurred.

The majority of these comments recommends and supports Board of Directors 
adoption of the GNSO-approved set of RAA amendments.  There is also support in 
three of the five comments for use of some form of incentives to encourage 
early adoption.  While one of the comments suggests an implementation procedure 
other than the one recommended, the key theme appears to be that the changes 
are a positive development and the sooner they can be adopted and implemented, 
the better.

Briefly, in response, ICANN plans to provide incentives in order to encourage 
early adoption of the amendments and will continue to consider all 
recommendations on the subject.  Regarding data protection, ICANN will continue 
to comply with ICANN's Procedure for Handling Whois Conflicts with Privacy Law 
and will refer the comment made here to the GNSO for consideration in 
additional amendments.

Next Steps
In a resolution from the Mexico City meeting, the Board of Directors has 
committed to "to act on approval of the amendments at the earliest opportunity" 
following this public comment period.

Attachment: raa-consultation-summary-09apr09-en.pdf
Description: raa-consultation-summary-09apr09-en.pdf

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