Rubens,

The process would be for calls to be filtered through ICANN.  ICANN would maintain contact phone numbers and email addresses for each registrar.

I’m presuming each registrar already has a point of contact for emergency situations.  For the smallest registrar, this is probably their personal cellphone.

Upon receiving the call from ICANN, the registrar decides what to do.  There is no obligation to keep attorneys on duty if they don’t want to.  All that’s required is to field the call and act rationally.  The definition of “act rationally” is deliberately not included.

ICANN would maintain a record of each incident, including the identity of the requester.  ICANN would have the authority to filter out requests that do not appear to require urgent attention.  ICANN would presumably treat requests from known trusted requesters more favorably than requests from unknown requesters.

Steve

On Mon, Jul 17, 2023 at 9:44 PM Rubens Kuhl via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:


> Em 17 de jul. de 2023, à(s) 15:09, Steve Crocker <steve@shinkuro.com> escreveu:
>
> If I heard correctly, the Phase I WG said they couldn’t reach agreement on the details and left it to the implementation team— that’s us — to work out the details.  In my view, that’s exactly where this proposal fits.
>
> If this group feels this proposal cannot be adopted because it doesn’t fit within the confines of the policy decisions made earlier, we’re going to wind up without a workable solution.  That will lead to reopening the policy process and returning to exactly where we are now.  Better for us to propose a workable solution.

With the difference that the policy process is only limited by the charter, while the implementation is limited by the policy outcome. So I wouldn’t assume that the policy process couldn’t achieve what the implementation team did not.

Also to note is that only the urgent request aspect of the policy would need a focused policy process. Everything else in the RegData PDP could move forward. So, instead of 2 business days, those requests would get up to 30 days for the time being.

>
> This proposal implies some expense for ICANN but little or no additional expense to registrars.

Last I heard lawyers are not free on any reasonable jurisdiction, so there is additional - and significant - expense to registrars.


Rubens

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