Joined registrar response to the revised ICM registry proposal

[Thomas Keller <tom@xxxxxxxxxx>]

Hereby we would like to raise our concerns in respect to a paragraph of the 
Proposed ICM Registry Agreement for .XXX Appendix S, Part 6, Public Whois 
Specification which reads as follows:

"Registrars will be required to participate in the operation of a 
cross-registry 
WHOIS database, which will provide searching capabilities and access to all 
information concerning domain name registrations regardless of which TLD the 
domain name is registered in or which registrar processed the domain name 
application."

The requirement resulting out of this paragraph is out of scope for this
agreement as it stands in no direct relation to the operations of the 
XXX registry.

It is our believe that substantial new and generic obligations to registrars 
should in any case be subject to the consensus policy process as mandated by 
the Registrar Accreditation Agreement 
(http://www.icann.org/registrars/ra-agreement-17may01.htm)
which is designed to implement such new policies in an open and transparent way.

As the paragraph in question establishes a new and generic obligation for 
registrars
we have to object to the inclusion of this paragraph in the final verion of the
XXX Registry Agreement.

With best regards,

Tom Keller 

Signatories:

Active 24
Ascio Technologies
Blue Razor Domains
Bulkregister
CORE
Domaine.fr
DomainPeople Inc.
eNom 
EPAG Domainservices
GMO Internet
GoDaddy.com, Inc.
Go Australia Domains Inc.
Go Canada Domains Inc.
Go China Domains Inc.
Go France Domains Inc.
Go Italy Domains Inc.
Melbourne IT
Network Solutions
Schlund+Partner AG
The Midcounties Co-operative Ltd.
Tucows
USA Webhost
Wild West Domains Inc.