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Re:  http://www.dnso.org/clubpublic/nc-whois/Arc00/doc00091.doc

Kristy,

With regard to your initial draft of the issues paper on WHOIS Searchability, 
I note that while you have referenced the RAA, you have overlooked citing 
Appendix W of the .com Registry Agreement:

1. Centralized Whois

Registry Operator shall develop and deploy a centralized Whois for the .com, 
.net, and .org TLDs if mandated by ICANN insofar as reasonably feasible, 
particularly in view of Registry Operator's dependence on cooperation of 
third parties.

2. Research, Development and Infrastructure Improvements

During the period between the Effective Date of this Agreement and December 
31, 2010, Registry Operator agrees to expend a minimum of US$200,000,000 for 
research, development, and infrastructure improvements to the .com, .net, and 
.org Registries (the "Improvements"). The intent of the Improvements is to 
increase the efficiency and stability of the .com, .net and .org Registries. 
Registry Operator shall ensure that a substantial portion of expenditures for 
the Improvements occurs prior to November 10, 2007. Registry Operator shall 
provide ICANN with an annual report on this research and development activity.

Registry Operator agrees that one of the early goals of the Improvements is 
to design and develop a Universal Whois Service that will allow public access 
and effective use of Whois across all Registries and all TLDs. Registry 
Operator shall commence research and development of the Universal Whois 
Service no later than December 31, 2001. Registry Operator shall, insofar as 
is reasonably possible in view of Registry Operator's dependence on the 
cooperation of third parties, strive to achieve significant progress in 
implementing the Universal Whois Service by December 31, 2002.

Registry Operator further agrees that if it successfully designs and develops 
the Universal Whois Service it will (a) make the Application Program 
Interfaces necessary to produce software which can efficiently deploy and use 
the Universal Whois Service available to applications developers on an open, 
non-proprietary, standards-based and royalty-free basis, and (b) make the 
Universal Whois Service available at a standardized reasonable fee to be 
negotiated with ICANN.

---------

On a related note, I would ask why VeriSign is charging registrars for 
provision of the RGP service if VeriSign has already contractually agreed to 
commit $200,000,000 for infrastructure improvements? Why should registrars 
(and in turn registrants) have to absorb these charges?

Best regards,
-- Danny --
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