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Username: Jean Cantrell
Date/Time: Mon, November 1, 1999 at 11:28 PM GMT (Mon, November 1, 1999 at 4:28 PM PDT)
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Subject: Comments of The Dun & Bradstreet Corporation



October 28, 1999

Ms. Esther Dyson
Interim Board Chair
Mr. Michael Roberts
Interim President
The Internet Corporation for
   Assigned Names and Numbers
4676 Admiralty Way
Suite 330
Marina del Ray, CA 90292

Dear Ms. Dyson and Mr. Roberts:

The 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 consideration.

 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 services.

 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.

From 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 effort.


Jean Cantrell
Director-Government Affairs
The Dun & Bradstreet Corporation
1200 New Hampshire Avenue, NW
Suite 440
Washington, DC 20036
202 463 2154


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