Hi Gabriel,

Please find my comments to your questions below in red.

Thanks

Lisa Carter

Sr. Program Manager, Strategic Initiatives

ICANN

From: Gabriel Andrews <gfandrews@fbi.gov>
Date: Thursday, June 6, 2024 at 11:18 AM
To: "gnso-rdrs-sc@icann.org" <gnso-rdrs-sc@icann.org>, Lisa Carter <lisa.carter@icann.org>
Subject: [Ext] RE: Email thread for discussing voluntary inclusion of ccTLDs

To continue the conversation:

@ Lisa:  Per your note that “all RDDS requirements for ccTLDs are Unstandardized/Unenforceable”, I think I might be missing your point, and hope to clarify ~

i. Speaking to “Unenforceable”, we seem to be in consensus that all RDRS participation is strictly voluntary, and that any ccTLD participation would also be voluntary.  

While participation in RDRS is voluntary, RDRS does rely on other contractual obligations for gTLD registries such as the availability and supported format of their WHOIS service (and RDAP in the future), obligations that do not exist for ccTLDs.

ii. As for “Unstandardized”, is this to suggest that the lack of standardization is preventing ICANN from determining whether/not a ccTLD request is associated with a participating registrar?  It was my understanding that the initial lookup done at the start of a RDRS request is always capable to determining the registrar, regardless of whether it’s gTLD or ccTLD.  Is that incorrect?  

Similar to the above response, for RDRS to determine a domain name’s sponsoring registrar based on the registry operator’s WHOIS service, the service must be compliant with the relevant policy and contractual requirements which are not applicable to ccTLD registry operators, and define the location and supported formats of the WHOIS service. Additionally, determining the sponsoring registrar of a domain name is done using identifiers that are applicable only to ICANN-accredited registrars, which may not be the case for domain names in ccTLDs.

iii. What LOE would it be to run the initial domain query as you already are, but only “error out for ccTLD” reasons if the query does not successfully identify a participating registrar?

We are still assessing the level of effort (LOE), but we would likely require additional analysis to agree on the desired behavior and to consider new scenarios. That being said, based on a preliminary discussion with the team and considering the reasons outlined above, the likely LOE has been estimated to be 'very high' as indicated in the Impressions Document.

@ all:   Having heard from a small # of ccTLD operators a desire to participate in RDRS,

i. Would voluntary ccTLD participation in RDRS help provide us lessons that might be factored into consideration of whether/how ccTLD voluntary mechanisms might be employed in a SSAD/ successor systems?

/ps - added below an edit to the initial email, w the critical clarification “ccTLD”

From: Andrews, Gabriel F. (STB) (FBI)
Sent: Thursday, June 6, 2024 10:51 AM
To: gnso-rdrs-sc@icann.org
Subject: Email thread for discussing voluntary inclusion of ccTLDs

Hi all –

Noting the desire to “clean up” the impressions document, I hoped to shift from a margin comment conversation to an email conversation for the specific issue of whether/not RDRS can pass requests to participating registrars regardless of whether/not the domain is a ccTLD.

Below are pasted the original feedback topic, and the subsequent margin comments. 

I will next respond to my own email (this) to continue the discussion, but wanted to make a clean break before adding anything new.

Cheers,

G

Gabriel Andrews

11:33 AM May 22

Pinned for further discussion.  Existing RDS/WHOIS queries provide this information a non-zero % of time - is this intended to say technical staff can't guarantee to have the info 100% of the time?  Clarity sought.

Anonymous

8:38 AM May 30

In other words:  what other info does ICANN tech staff think is needed in order to route the request to the registrar as is done in gTLD contexts?

Anonymous

8:39 AM May 30

Additionally:  PSWG is hearing from some ccTLD operators their desire to voluntarily participate in RDRS, which may assist in solving any challenges.

Lisa Carter

9:03 AM Today

Just an FYI that RDDS requirements for ccTLDs are Unstandardized/Unenforceable as there is no contract for ccTLDs with ICANN.