Comment: Proposed Renewal of .asia Registry Agreement
The ALAC supports the proposed changes to the .asia (DotAsia) renewal agreement, with (3) comments related to universal acceptance (UA), public interest commitments and fees to be paid to ICANN org.

Comment: ALAC Statement on Registry Agreement Renewals .org, .biz and .info

The ALAC generally refrained from commenting on these prior proposed Registry Agreement renewals, with the exception of the proposed renewal of the .NET Registry Agreement in 2017. The ALAC in general favors standardizing Registry Agreements as this allows for transparency and predictability, as well as ease of review and compliance monitoring of one standard contract (with necessary but controlled variations through Addendums) instead of managing many disparate/varying contracts. Being supportive of this approach, the ALAC has not objected to the base Registry Agreement, or to its use in prior renewals.

In respect of the intent to standardize the said 3 proposed Registry Agreement renewals (.org, .biz, .info), the ALAC
welcomes the following proposals:

(i) inclusion of Public Interest Commitments (per Specification 11),
(ii) inclusion of Minimum requirements for Rights Protection Mechanisms (per Specification 7),
(iii) adoption of the Registry Code of Conduct (per Specification 9), and
(iv) amendment of the relevant section in Specification 5 to govern the allocation of two-character labels at the second level to avoid confusion with corresponding country codes.

The ALAC also noted there are differences in opinion within At-Large regarding the omission and quantum of price caps.

Advice (sent to ICANN Board): GNSO Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Policy Recommendations for ICANN Board Consideration

The ALAC provided advice to the ICANN Board, noting significant concern related to three aspects of the EPDP Report. Specifically, the ALAC is concerned not only with the outcomes, but with the process that was followed to address the issues. All three impact the ability to access registration data and the completeness of that data, specifically: “to identify the appropriate balance for a path forward to ensure compliance with the GDPR while maintaining the existing WHOIS system to the greatest extent possible”. The ALAC advises the ICANN Board to:

Request that the issue of Thick WHOIS be discussed during the EPDP Phase 2 in light of the new legal opinion;
Request that the issue of geographic differentiation be re-opened during the EPDP Phase 2 in light of the new legal opinion and the lack of considering the competing needs of privacy vs the benefits of non-redaction on cyber-security activities and that the ensuing discussion factor in the needs of those using the data for cyber-security and other legitimate purposes;
Request that the issue of legal/natural differentiation be discussed during the EPDP Phase 2 explicitly considering the competing needs of those using the data for cybersecurity and other legitimate purposes;
Initiate independent studies related to the implementation of geographic and legal/natural differentiation as well as the impact of the Temporary Specification implementation on cyber-security, or request that the EPDP Phase 2 commission such studies. If the latter, the Board should ensure adequate funding for such work.

Public Comment for Decision

None

Current Statements (ALAC Advice, Comment or Correspondence)

None

Public Comment for Decision

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Current Statements (ALAC Advice, Comment or Correspondence)

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Penholder(s)

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