* Antony Van Couvering wrote:
1. Why if it has to do with Port 43 are unreachable websites considered a fail? That would make sense for web-based Whois, but not for Port 43.
The RAA requires both. Port 43 is the well known port for WHOIS. Naming the web access port would cause confusion (as naming the other port number).
2. Why is rate-limiting considered a fail? This is put in place by responsible registrars to prevent scraping of Whois data by spammers.
The AoC requires ICANN to provide "an unrestricted, public access to complete and timely data" in terms of WHOIS. Rate limits are - strictly speaking - illegal for ICANN accredited registrars. But ICANN tolerates use usage. If a service is unreachable, too strict rate limits might give the cause. So they investigated "unreachable WHOIS" further and throw out rate limits as a possible cause.