In February of 2020, ICANN published its Initial Report of the Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Team – Phase 2, followed by an addendum in March. InfoNetworks submitted detailed public comments on the report highlighting several key areas of concern (that the InfoNetworks approach addresses). One of the issues is the need for access to information regarding “beneficial registrants” who register their domains using a privacy service. We noted that ICANN is currently creating a system only for accessing the official domain registration data itself, which primarily contains proxy information, and not addressing the true registrant data held by privacy-proxy services. Obtaining basic registration data will not likely assist with addressing the party responsible for online abuse using their domain name—core to the vital public interest for WHOIS. Another issue that we highlighted is the need to delineate registrant data that is not governed by the GDPR or other data privacy regulations. We noted that a significant portion of domain names are registered to legal persons and/or for commercial purposes, where the registrant identity and contact information may either not be governed by the GDPR at all, and the public interest of combating domain abuse should be considered in determining whether to disclose the data. These same concerns have also been noted by the European Commission in its correspondence with ICANN.