Dear Alan & ATRT-2 members, I wanted to provide additional insight in response to the comments reflected in the draft analysis of the WHOIS RT implementation activities, for the ATRT-2's consideration. Most of these comments were shared during the ATRT2's last face to face meeting. 2. Regarding the Delay of Providing the Single Source Summary- Staff has noted in prior discussions with the ATRT-2 that Staff had been waiting for the contract negotiations to conclude for the 2013 RAA (27 June 2013), the New GTLD Agreements (2 July 13), and the renewals of existing registry agreements (.org, .biz, .info) (22 Aug 13), in an effort to ensure that the summary descriptions were up to date. Now that these agreements have been approved, Staff is planning to update the WHOIS Informational Website with a detailed summary of the entire WHOIS policy & contract requirements by the end of this month. 3. Regarding Outreach Activities, the ATRT-2 has asked for the detailed Communications Plan. Please find attached an updated plan from the Communications Department. 4. Regarding the Compliance Staffing Levels- the ATRT-2 has asked for additional clarity regarding the Compliance Department's budget & expectations. Here is the information I received from Compliance: * Current Staff counts: 14 Staff members strong (+ 1 open position), covering the following languages: Arabic, English, French, Hindi, Korean, Mandarin, Russian, Spanish and Urdu * For FY14, the Compliance Department has approval to add 4 additional head-counts, and is planning through these positions to establish global presence in ICANN's hub offices * In comparison, in April, 2011, Compliance Dept. Staff consisted of 7 members Regarding the Transparency of the Compliance Department, there are other ways that Compliance reports its progress, beyond the Staff's monthly compliance reports-including webinars, blogs, reports through myicann.org, sessions at ICANN Meetings, to name just a few. Please refer to the Implementation Milestone Chart previously distributed for more details. Regarding the statement that the "[u]sage of such terms as "Prevention Complaint Volume" to describe the number of complaints received is at best confusing and at worst deceptive".... , while it may not have been intended, it comes across as rather harsh to describe the Compliance's work as deceptive, as this implies malicious motives. Although the choice of terms might not adequately reflect the metric being depicted, Staff suggests that the description could be revised to be less inflammatory -- or perhaps replaced with a suggestion that the title be revised for accuracy. 5. Data Accuracy- Regarding the statement of 100% completion with regard to the EWG model, this was taken from a phrase included in the spreadsheet originally provided to the ATRT2. "100%" was a shorthand reference to the initiation of the EWG and its work. Staff did not mean to convey that the EWG work was complete. 8. Regarding the WHOIS verification goals for the 2013 RAA, while it is true that ICANN initially sought more expansive WHOIS validation/verification requirements, questions were raised related to the costs associated with implementing them on a global basis. For this reason, the final 2013 RAA did not include them. 12. IRD- Regarding the comment that ICANN propose interim requirements, Staff has clarified that this might be problematic as it could result in having registries/registrars incur transition costs to meet the interim rules for a temporary basis, only to incur additional implementation costs when the recommendations of the IRD Group and the GNSO PDP on translation/transliteration are finalized. Thank you for considering these comments, and for all of your feedback on the WHOiS implementation activities. All the best, Margie ____________ Margie Milam Senior Director- Strategic Initiatives ICANN ____________