Dear All, Whilst the SSAC has recommended to the Board to defer all activities until the Registration Data Policy is created, then it follows that there could be a considerable delay. The implications in my mind could mean the suspension of the "Thick Whois Charter" etc. However, I am of the view that the Registration Data Policy should be initiated and there can be things done simultaneously to ensure that things are expedited. To this end, I would suggest the following: However, if we take the view that things can be developed simultaneously, it follows that there are things can be initiated in the interim pending a Registration Data Policy and this could include things like getting the GNSO to do the following:- *Phase 1* · Finalize GNSO Whois Studies [should have been completed in 2012]; · Draft paper modeled around the findings Council of European National TLD Registries as a starting point for policy discussion on the matter and initiate Public Consultations; · Mapping out models to include potential scenarios of architectural solutions:- o Model 1 – Thick Whois o Model 2- Thin Whois; o Model 3- Mixture of Thick and Thin Whois; o Model 4- other. [Initiating Public Consultations to receive feedback on the models] Upon receipt of the results of the GNSO Studies, to work out the different possible Models that are workable. Assuming that within Phase 1, the Registration Data Policy would be completed. *Phase 2* · Finalize the models based on the Registration Data Policy and results of the GNSO Whois Studies; [Public Consultations and feedback] · Leverage the discussions of the paper on the findings of the Council of European National TLD Registries as a starting point for policy discussion on the matter factoring in the GNSO Whois Studies · Harmonization in accordance with the Registration Data Policy and finalizing solution for Whois [public consultations] *Phase 3* · Launch the solution What was unequivocally clear from the Whois Review Final Report, that there were competing views on the use and dissemination of data. Whilst recommendations were made there was no concrete discussion on the use and dissemination of data. I agree with Alan that the “recommendations clearly make sense” and perceive as “fair comment” his views that these are issues been debated for years. However, I would add caution to the wind and say that they have been long debated without clear concrete resolutions and outcomes and this can be attributed to the entire community. Which is why I find the SSAC’s use of the “blind men and the elephant” and apt analogy of describing the state of how different “interests” perceive and describe remedies and solutions or approaches. The issues is not that they are blind nor is it about insinuating incompetence, it just shows how people wrangle and hold onto diverse positions without fully comprehending the situation from a holistic manner. Having said that there were critical controversial issues from divergent legislative approaches from prioritization of rights (privacy, data protection, intellectual property) and liability of intermediaries etc. Of relevance, are the current GNSO Whois studies[1] <#_ftn1>. If we examine the SSAC’s strict recommendation where the Board should defer all activities in finding a solution on the Whois until there is a Registration Data Policy[2] <#_ftn2> then it follows there could be a considerable delay and it would also mean that the Thick Whois Charter is effectively suspended in the interim pending resolution of the Registration Data Policy. The SSAC holds the view that the Board should defer all activities in finding a solution on the Whois until this is done. However, if we take the view that things can be developed simultaneously, it follows that there are things can be initiated in the interim pending a Registration Data Policy. ------------------------------ [1] <#_ftnref1> http://gnso.icann.org/en/issues/whois/studies see: Whois Misuse Study; Whois Proxy and Privacy Abuse; Whois Registrant Identification and Whois Proxy & Privacy Relay and Reveal Study which the Report says is due for completion in 2012 and cost $530,000. The considerable delay in concluding those Reports where now we are told that these may be completed in 2013. [2] <#_ftnref2> http://www.icann.org/en/groups/ssac/documents/sac-055-en.pdf