I've reviewed this draft and have a couple of questions and comments.
And with some of my questions, I may be reading this too literally, so
please forgive me in advance.

Section 2 paragraph 5 says:
"Note that the legal definition of any of the terms used in the data
dictionary, such as 'personally identifiable information' or 'legal
person', are to be determined locally. The organization using this
dictionary will record their interpretation in the appropriate
element."

The last sentence confuses me. What organizations are recording their
interpretation and where are they doing it?

Section 2.4, 2.5, 2.6, and 2.7
These all mention dates as element names but then specify "date and
time".  In some cases, it may be that time is optional. I don't feel
strongly about it or have any good examples, but wonder if the
flexibility should be given.

Section 2.14
The element name is "User Account ID" but the description says
"customer ID". Those can be two different things, one identifying a
person and one identifying an account. That is, a person can have one
or more accounts.

Section 2.27
The element name is "Email_or_phone" but the description talks about
reachability. This seems to be disjointed. And what does confirmed to
be reachable mean? If an email doesn't bounce, is that reachable? If a
telephone number results in ringing, is that reachable? I've seen
other terminology used such as "validated" and "verified". Some
references:
https://www.arin.net/participate/policy/nrpm/#3-6-annual-validation-of-arin-s-public-whois-point-of-contact-data
https://validation.apnic.net/confirmation
https://www.icann.org/resources/pages/contact-verification-2013-05-03-en
The methods for each vary, so this seems hard to define.

Internationalization Considerations
"The character encoding for the file contents MUST use UTF-8.
Throughout this document A-LABEL is indicated as a SHOULD and that
MUST be interpreted as follows. All name labels MUST be in A-LABEL
format if it is possible to represent it as an A-LABEL, otherwise
U-LABEL MAY be used."

Is the file referenced in the submission for the IANA registry? And
what is supposed to be an A-LABEL, the domain part of the registrant's
email address?

-andy

On Mon, Feb 13, 2023 at 9:03 AM James Galvin <gal...@elistx.com> wrote:
>
> This is a reminder to please indicate your support or no objection to the 
> publication of this document.

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