ICANN’s Registration Data Request Service cost hundreds, maybe even thousands, of dollars every time it was used in its first year, according to an analysis of official stats.
RDRS is the system designed to connect entities such as trademark owners, security researchers, and law enforcement with registrars, allowing them to request private domain registration data that is usually redacted in Whois records.
It’s running as a two-year pilot, in order to gauge demand and effectiveness, and its first full month of operation was December 2023.
ICANN has been publishing monthly transparency reports, including data such as number of requests and outcomes, and we know how much it cost the Org to develop and operate, so it should be possible to make some back-of-the-envelope calculations about how much each request costs the ICANN taxpayer.
The cost could range from about $300 to over $3,000 per request, even using some fairly generous assumptions.
RDRS cost $1,647,000 to develop, which is pretty much a shoestring by ICANN standards. Most of that was internal staffing costs, with some also being spent on external security testing services.
The total operational cost for the first 10 months was $685,000. Before ICANN publishes its calendar Q4 financials later this month, we could extrapolate that the first 12 months of operation was around $800,000, but let’s be generous and stick with $685,000 for this particular envelope’s backside.
While there were 7,871 registered requesters at the end of November 2024, they had collectively only submitted 2,260 requests over the same period.
Only 2,057 of those requests had been closed at the end of the period, and only 23% of closed requests resulted in registrar approval and data being fully handed over to the requester.
That works out to 474 approved requests in the first year.
With the most-generous assumptions, $685,000 of ops costs divided by 2,260 requests equals $303 per request.
If we only count approved requests, we’re talking about $1,445 per successful Whois lookup equivalent.
But we should probably switch to an envelope with a larger rear end and include the $1.6 million development costs in our calculations too.
If we factor in half of those costs (it’s a two-year pilot), we’re looking at about $666 per request or $3,181 per successful request in the first 12 months.
If the system was more widely used, the per-request cost would of course fall under this calculation, but there’s no indication that usage is significantly on the increase just yet.
These are only the costs incurred to ICANN. Registrars on one side of the service and requesters on the other also bear their own costs of working with the service.
Dealing with RDRS is not the same as doing a Whois lookup. You have to deal with a much lengthier form, add attachments, make a reasoned legal case for your request, etc. It eats work-hours and staff need to be trained on the system.
It may seem that $3,181 to do a Whois lookup is too expensive for the ICANN taxpayer.
And maybe it is, if it’s being predominantly used to assist (say) Facebook’s trademark enforcement strategy.
But if those Whois lookups help law enforcement more quickly nail a gang of fentanyl dealers or child sexual abuse material distributors, maybe the costs are more than justified.
At the end of November the number of requests from law enforcement was 15.6% of the total, while IP holders accounted for 29.7%, ICANN stats show.
ICANN’s board of directors will decide towards the end of the year whether the RDRS pilot has been successful and whether it should continue indefinitely.
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