Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
Submissions for this Proceeding
Registration Data Request Service Standing Cmte. Report for GNSO Council Review
View this Proceeding
My Submissions
Search Public Comment Submissions For This Proceeding
To search for keywords within Public Comment submissions documents or pages, type in the keyword and press Enter after each selection.
Submission Summary:
Namecheap, Inc. appreciates the efforts of the Registration Data Request Service (RDRS) Standing Committee, the Standing Committee leadership, and ICANN Org in drafting the Report for the GNSO Council’s review. Namecheap supports maintaining the RDRS as a voluntary system for registrars. Any improvements to the RDRS and continued operation should be funded on a cost-recovery basis, with requestors covering the expenses. In the alternative, the...
Submission Summary:
INTA does not support continued operation of the RDRS. Frustration from both sides of the request equation points to the poor design of the system. Echoing the position of the IPC, INTA supports the development and implementation of a disclosure system, as distinct from a mere ticketing or communication system, that mandates participation by all contracted parties, incorporates practical authentication mechanisms, implements clear evaluation s...
Submission Summary:
Please find attached (PDF) the ALAC Statement on Registration Data Request Service Standing Committee Report for GNSO Council Review. Ratification information is included on the cover page.
Kind Regards,
ICANN Policy Staff in support of the At-Large Community
Submission Summary:
The RrSG appreciates the work of the RDRS Standing Committee and SC leadership team as well as ICANN Org in drafting the Report for the GNSO Council’s review.
The RrSG considers the RDRS project a great success as it did gather relevant and useful data; with this information on hand, the Board has the data it requires to make this decision.
The RrSG supports many of the Standing Committee's recommendations, an...
Submission Summary:
Tucows thanks the Standing Committee and their leadership team as well as ICANN Org for their work on this important Report.
Tucows supports many of the SC's recommendations, as well as the SC's determination that adoption of EPDP Phase 2 SSAD recommendations is not in the best interest of the ICANN community or ICANN and termination of SSAD proof of concept.
The RDRS pilot project has successfully demonstrated that building ...
Submission Summary:
The BC welcomes the RDRS Standing Committee Report and values its insights for shaping a permanent system to access non-public gTLD registration data. The RDRS pilot showed clear business need but exposed major flaws: high denial rates, excessive “user friction,” limited registrar participation, and lack of transparency in denials. The BC urges enhancements including APIs, UX redesign, clearer registrar guidance, inclusion of privacy/proxy pro...
Submission Summary:
The IPC does not support continued operation of the RDRS as it is currently structured. While we recognize the value of maintaining some form of interim non-public data access mechanism, the current RDRS has fundamental structural deficiencies that undermine its effectiveness and utility for consumer protection, intellectual property and law enforcement purposes.
The system suffers from lack of contracted party participation, significant...
Submission Summary:
The RySG is generally supportive of the report and the recommendations contained within, and offers additional comment on Recommendation #3, Recommendation #4, and Recommendation #5.
Submission Summary:
At a high level, it remains the view of the GAC that a functioning system enabling lawful access and submission of disclosure requests regarding domain name registration data is essential to ICANN’s mission of ensuring “the stable and secure operation of the Internet’s unique identifier(s)”. 1 Lawful access to registration data “helps achieve many such public policy interests, including enhancing trust in the DNS, ensuring consumer protection,...
Submission Summary:
Throughout our comments, we underscore that registrars must not simply render requests. They should conduct a documented evaluation of the fundamental rights at stake — including privacy, freedom of expression, and due process, and provide a clear rationale for any decision to disclose the information. This is not only a best practice; it is necessary to ensure registrant rights are not subordinated to expediency or automation.
In ...
Submission Summary:
I welcome the recommendation of the Standing Committee to continue the RDRS beyond its pilot phase and to begin introducing authentication for specific requestor groups, particularly law enforcement. From my perspective as a lawyer in Nigeria working at the intersection of cybersecurity and privacy, this step is critical. Authentication is not just a technical adjustment, it is a legal and trust safeguard. In Africa, where the Cybercrimes Act ...