October 28, 1999
Ms. Esther Dyson
Interim Board Chair
Mr. Michael Roberts
The Internet Corporation for
Assigned Names and Numbers
Marina del Ray, CA 90292
Dear Ms. Dyson and Mr. Roberts:
Dun & Bradstreet Corporation welcomes the opportunity to comment on the proposed
Agreements between the Department of Commerce and NSI; between the Internet Corporation
for Assigned Names and Numbers (ICANN) and NSI; between NSI acting as the registry
for the TLD Registry and the registrars; and between ICANN and the registrars, and
the accompanying documents.
We believe that these Agreements constitute a significant
step forward towards the viable, private sector operated Domain Name System envisioned
by the Department of Commerce White Paper entitled “Management of Internet Domain
Names and Addresses”. The Agreements demonstrate that having faith in
the private sector working with the U. S. Government to resolve issues and establish
a consensus-based DNS was wise policy. We appreciate that the process of reaching
agreement was not an easy one. The history of private sector Internet governance
efforts clearly indicates how difficult it was to do. Those involved should
take pride in this success.
The Agreements are detailed and complex. They
also reflect compromises needed to reach agreement. While we could suggest
changes that would make the Agreements better from our perspective, to do so might
threaten to unravel the compromises reached in order to obtain the agreements.
We do not find any single issue or set of issues sufficiently troublesome to risk
making major changes that could jeopardize the existence of these Agreements and
the promise they present.
Nonetheless, we offer two suggestions for your
First, access to registration data is very important for
several reasons. It is essential to guard against fraud and cybersquatting
on the Internet. And, it will be the basis for new, valuable services and products
for consumers that are developed from the private sector adding value to these registration
data. It is not entirely clear that sufficient data will be furnished through
bulk access to third parties from the TLD Registry at economical prices and comprehensively
or that they will be made available from the registrars economically and comprehensively.
While we support the movement towards a distributed network for access to registrar
data in a WHOIS-type query, we hope that all registration data can be provided via
bulk access and that such data is sufficient to be the basis of new products and
Second, in most US laws dealing with data privacy, the definition
of personal information refers to information about an individual acting on his or
her own behalf. Existing statutes were designed to protect the privacy interests
of individuals. An Individual who serves as an officer, principal or employee
of a business does so on behalf of that business and should not, therefore, receive
the same level of protection that he or she may receive when acting on his or her
own behalf. Unfortunately, this distinction is not clearly drawn in the Agreements
in its reference to personal data. Because it is an important distinction,
we believe it should be spelled out in greater detail to avoid confusion.
the beginning, Dun & Bradstreet has supported the process of transitioning the management
of domain names from a government run system to a private sector run system.
While the process has not always been easy, we believe that the collaboration, thus
far, between the Department of Commerce and ICANN has resulted in achieving the critical
goal of ensuring the stability of the Internet. As always, we appreciate the
opportunity to comment and look forward to continued participation in this important
Dun & Bradstreet Corporation
1200 New Hampshire Avenue, NW
202 463 2154