On June 9 CircleID published an insightful article by Thomas Rickert entitled “Demystifying Art 28 NIS2.” In that piece Thomas set forth two alternative interpretations of Article 28(6) of NIS2, and argued that TLD registries should not be required to maintain a separate database of the registrant data under NIS2. In my view, Thomas’ approach is inconsistent with the remainder of Article 28, and would not achieve the goals of NIS2 to improve cybersecurity across the EU member states.