Wolf-Ulrich,

Regarding the proponed RAA these are my comments:

With respect to the contended articles:

3.3 Public Access to Data on Registered Names. I support ICANN’s proposal, I think is better to have more than less access to information, the party accessing the Data Base doesn’t necessary know if it is a “thin” or “thick” WHOIS.

6.3. ICANN’s proposed 6.3 article seems excessive, there can be no unilateral amendment of a bilateral agreement. Perhaps there should be some speed up process of amendment for exceptional occasions when a change is needed urgently, but it has to be agreed upon by a majority of the registrars.

6.7.2. I think it should be enough with more than 50% of the Applicable Registrars.

With respect to the document in general, and considering other comments that have been published:

I think it is reasonable to require that all new gTLD registries use registrars that have signed the 2013 RAA, it is a way of speeding the incorporation of the new RAA among all the registrars. Supposedly the majority of the registrars will have agreed with the new RAA at the end of the negotiations.

I think it is a good idea to require the registrars to list a point of contact at their company to handle WHOIS compliance issues.

Best regards,

Osvaldo

De: owner-ispcp@gnso.icann.org [mailto:owner-ispcp@gnso.icann.org] En nombre de WUKnoben
Enviado el: Jueves, 21 de Marzo de 2013 06:43
Para: ispcp@icann.org
Asunto: [ispcp] Public comment on RAA

All,

as you know the public comment period on the new RAA is coming to a close one week from now (28 Mar). The draft has several times been discussed publicly and at the council. There’s not yet consensus on all issues raised.

I would appreciate input until Saturday this week that could be combined as an ISPCP comment. I would then provide a draft by Sunday.

On Monday I’ll go on travel to Asia and shall have limited web access. So it would be helpful to finalize the comment this weekend as far as possible.

Thanks and best regards

Wolf-Ulrich