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1. Looking at the specific example, having a common third party for all gTLDs is, to some extent, counter to the intent of having registries spread around the world. It centralizes where the long-term intent is to decentralize. Even if a less centralized approach is taken where there are multiple Whois providers, presumably certified or acredited accredited by ICANN, we end up with ICANN taking on a new responsibility without any real substantive benefits. Moreover, it takes a level of control out of the hands of the Registry. This level of control has been important when one looks at the tiered access that some Registries provide to meet local/regional privacy concerns.
2. In the more general case, opening up this PDP to an overall review of Whois models (and perhaps ultimately the Whois concept itself) will take what appears to be a relatively straight-forward issue and transform it into the global Whois debate, That debate is being addressed in a number of other ways at the moment, and the GNSO should take care to ensure that this limited PDP does not morph into the larger and far more contentious issue.
3. Lastly, consideration of alternate Whois models does not make sense in relation to just a few gTLDs, all the more so when there are other activities in ICANN that are at this time considering the more general Whois question, potentially including alternative models.

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