In March of 2019, ICANN’s Technical Study Group published its Draft Technical Model for Access to Non-Public Registration Data for community review and InfoNetworks submitted our detailed public comments. While the TSG incorporated some of our recommended changes into their final report, the primary concern highlighted in our comments ICANN’s assumption that its centralized model would, ipso facto, reduce liability for Registrars and Registry Operators. We explained how centralizing access through ICANN would NOT inherently reduce liability and that a legal framework was needed for allocating liability. This was echoed in the published legal memo prepared for ICANN, and in similar comments made by the European Data Protection Board and the European Commission in their subsequent correspondence with ICANN.