Thanks to Steve and the drafters for all this work. I am speaking from memory on the EWG's report, as I have not had time ro re-read it, so apologies if these have already been raised. However, I do think there are some points the BC should consider: Any contractual obligation placed on any part of the domain name supply chain (be it registries, registrars or registrants) MUST NOT contravene local law. This is especially true for data privacy issues, which are a major point of focus in Europe for example. The recent debates over the latest RAA (as a reminder, some European registrars are finding themselves unable to sign the RAA, and therefore unable to sell new gTLDs which pust them at a competitive disadvantage, because it goes against their local privacy laws: http://blog.blacknight.com/blow-fuse.html) show that any WHOIS work must also take these obligations into account. I am worried that the EWG does not seem to have taken more than a passing glance at ccTLD WHOIS obligations such as those placed on the French registry by the French national data privacy agency (CNIL). Looking at this more closely would highlight the need for opt-out clauses for those who'se national laws would prevent them enacting any EWG recommendations as-is. In short, I think our message here to ICANN should also be: learn from the current RAA mistakes! Another point I have made before is that I believe as representatives of businesses worldwide, we should continually nudge for this work to encompass ccTLD WHOIS as well. We have all heard before the many reasons why the EWG should not be doing so, but as businesses, do we really think it's OK to have such extensive work be done on gTLD WHOIS only? The level of confusion this risks generating for businesses that are not domain savvy, and may not understand that there are different rules for, say, .COM and .DE, should not be underestimated. Thanks, Stéphane Van Gelder Chairman and Managing Director/Fondateur SVGC.net T (FR): +33 (0)6 20 40 55 89 T (UK): +44 (0)7583 457053 Skype: SVANGELDER www.StephaneVanGelder.com www.svgc.net ---------------- Follow us on Twitter: @stephvg and "like" us on Facebook: www.facebook.com/DomainConsultant LinkedIn: fr.linkedin.com/in/domainconsultant/ On 18 February 2014 04:22, Steve DelBianco <sdelbianco@netchoice.org> wrote:

Attached are draft BC comments and questions on the Status Update from the expert working group on gTLD Directory Services.

The EWG status update is here<https://urldefense.proofpoint.com/v1/url?u=http://www.icann.org/en/groups/ot...>, and described on this page<http://www.icann.org/en/news/announcements/announcement-11nov13-en.htm>. Comments close 28-Feb, so today begins a 12-day member review period.

Thanks to BC members Jimson Olufuye, Tim Chen, and Susan Kawaguchi for this drafting work.

Jimson is the CEO of Kontemporary, a systems Integration and ICT Consultancy firm. Though less than 10% of the company revenue is from domain businesses, he has interacted extensively with gTLD and ccTLD WHOIS registry systems.

BC members are familiar with Susan's many years of work to improve WHOIS, first with eBay and now with Facebook. Susan was appointed to the WHOIS review team two years ago and is now a member of the EWG on Directory Services.

Tim is CEO of DomainTools, whose products partly rely on whois data to help users understand who operates a given website or IP address, and to also make connections between domain names. DomainTools' clients include law enforcement, trademark attorneys, cybercrime investigators, brand protection agents, and a wide variety of professionals in the DNS industry.

All BC members are invited to REPLY ALL with edits (using TRACK CHANGES, please).

Note that the second half of this draft shows a dialog between Tim and Jimson regarding certain aspects of Directory Services. Based on member feedback, we will refine that section into additional points or questions for the EWG.

-- Steve DelBianco Vice chair for policy coordination