As CTO of CentralNic I have been involved in both the development of the RDAP core protocols and the RDAP Pilot Program. CentralNic is a Registry Services Provider to 75 generic TLDs, and, being based in the EU, is directly subject to the General Data Protection Regulation. I agree with almost all of ICANN org’s proposed changes to the RDAP profile, with one exception, which is #27 (“Require implementation of searchability in RDAP once an RFC provides such functionality”). This proposal forces registries which have ICANN’s permission to offer searchable whois services to offer an RDAP search service. However, these registries are under no obligation to offer such a service, and in fact many have withdrawn these services due to the GDPR (ICANN’s “permission” notwithstanding). It is not appropriate to force these registries to offer an RDAP search service. Instead, they should merely be permitted to do so, in the same way they are permitted (but not obliged) to offer a searchable whois service. Regards, -- Gavin Brown Chief Technology Officer CentralNic Group plc (LSE:CNIC) Innovative, Reliable and Flexible Registry Services for ccTLD, gTLD and private domain name registries https://www.centralnic.com/ +44.7548243029 CentralNic Group plc is a company registered in England and Wales with company number 8576358. Registered Offices: 35-39 Moorgate, London, EC2R 6AR.