NIC.br comment on GAC Safeguard Advice

[Rubens Kuhl <rubensk@xxxxxx>]

> "We welcome the GAC Input on the topic of safeguards applicable to all new 
> gTLDs. Although some ideas are unfeasible, most measures of improvement to 
> WHOIS accuracy are possible and would bring a higher degree of trust in the 
> Domain Name System. A signification portion of those will be in place in the 
> gTLDs we've applied to even without a guidebook requirement of such 
> provisions. We expect though these safeguards to be uniformly applied to all 
> gTLDs, both new and pre-existent.  Most of the gTLD domains used in the DNS 
> will still be from pre-2013 TLDs for the years to come, and imposing burdens 
> only on new gTLDs might hinder program objectives such as increasing 
> competition and consumer choice. When such measures are applied through 
> Consensus Policies, all gTLDs are required to follow and have contractual 
> oversight of compliance. We also note that most of these topics are currently 
> being discussed in the Expert Working Group on gTLD Directory Services, so 
> any commitment at this point would possibly require modifications after the 
> GNSO Policy based on the Working Group output is passed. Considering 
> Consensus Policies are enforced on gTLD contracts through the Picket Fence, 
> we think no Public Interest Commitments to address this advice are needed."

NIC.br