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For information about this Public Comment, please click here 
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FINAL VERSION TO BE SUBMITTED IF RATIFIED

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The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.

 

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FIRST DRAFT SUBMITTED

ALAC Statement on the Next-Generation gTLD Registration Directory Services to Replace WHOIS Preliminary Issue Report 

The ALAC strongly supports the research and recommendations in the Preliminary Issue Report. We are particularly impressed by the report’s clear, coherent summary of the milestone policy development activities, studies, and implementation efforts pertaining to WHOIS.

WHOIS is and remains a priority issue of focus for the ALAC and our engagement in WHOIS policy development activities has been extensive and profound throughout the years. The ALAC has formed the following position and wishes to reiterate: Before creating any new policy framework for a next-generation Registration Directory Services (RDS) to replace the legacy WHOIS system, the fundamental questions regarding the purposes, uses, collection, maintenance, and provision of registration data must be addressed. The ALAC is pleased to see that the report concurs with our long-held position. 

The ALAC supports the proposed Policy Development Process (PDP) as a whole, including the ICANN staff recommended 3-phase approach for organizing the work. Specifically, “the proposed issue raised for consideration” (2.2.a.), which concerns the fundamental questions about WHOIS, will point this Board-initiated PDP WG in the right direction to start its work. Furthermore, the ALAC strongly agrees with the ICANN staff recommendation that the PDP should proceed only after careful consideration of the recommendations by the Expert Working Group on gTLD Registration Directory Services (EWG). The EWG Final Report enumerates several inter-related WHOIS policy concerns, and the PDP needs to move the EWG process forward by analyzing the fundamental elements, purposes, and requirements of the gTLD registration data in order to determine if and why a next-generation RDS is needed to replace WHOIS. We too endorse the notion that a successful outcome of this PDP is important to resolve a multitude of problems identified in the legacy WHOIS system.

The implementation of the PDP’s proposed Process Framework will be of heightened interest to the ALAC. The ALAC hopes and trusts that sufficient measures will be put in place to ensure equitable and representative participation of all stakeholders in the PDP, where members consider all views and are willing to forge consensus.

End user community engagement in this PDP is a major concern. The ALAC believes that this critical subject needs broad community inputs and requires extraordinary measures to ensure high level of multi-stakeholder participation. While the Draft Charter indicates that the PDP WG will be “open to all interested [parties],” the long-term time commitment that this PDP demands – not only within the overall PDP WG but also in the series of sub-groups that the 3-phase process may potentially create – can hinder equitable participation. The ALAC is concerned that volunteers from the end user community, whose participation is only possible by carving out time away from work and life commitments, will face extraordinary challenges. From our experience, the complex issues in this PDP will almost certainly require face-to-face meetings of the PDP WG and future sub-groups, and this will impose financial constraints to the participation of end user volunteers. As a consequence, the end user voice may very well be stifled by the voices of interested parties who participate in the PDP as part of their jobs in support of their business needs and receive assistance from their organizations.

The ALAC will be vigilant to ensure that measures to enable the broadest participation in the PDP WG and sub-groups are considered and implementedThe first draft submitted will be placed here before the call for comments begins.