RE: [bc-gnso] Draft Comments on ICANN's Study of the Accuracy of the WHOIS Registrant Contact Information

[Marilyn Cade <marilynscade@xxxxxxxxxxx>]

Thanks, Susan, for your development of the BC comments, and Steve, for your 
addition.
I wonder if the comments need a paragraph or at least a sentence or two that 
also notes the importance of WHOIS to business, and the long standing 
involvement of this constituency in WHOIS issues; our concern about issues like 
fraud, abusive registrations, misuse of domain names to engage in phishing, and 
other deceptive practices. 
WE should take care to distinquish the concerns of the BC as being focused 
about concerns that come from the perspective of business users.  Business 
users are concerned about abusive use of registered domain names because 
abusive use or misuse adds in risks to users of the Internet; leads to fraud 
and other problems.  Accurate and available WHOIS is a critical part of 
ensuring trust on the Internet. Such a paragraph could be an introduction, or a 
closing statement as an addition to the comments. 
I agree, broadly with Steve's additions but offer a couple of suggestions for 
your consideration:
I might reword number 5 a bit.
We want ICANN to continue regularly scheduled WHOIS accuracy analysis and 
publish it, as they have with this report. We further believe that such fact 
based analysis can help to identify the needed areas for improvements in 
registrar fulfillments of their responsibilities to gather, publish and 
maintain accurate and accessible WHOIS. 
I would perhaps change the statement "Registrars manage to gather... ", to 
read:  "Processes to gather accurate information are undertaken by Registrars 
in the collection of credit card and other form of payment information.  Valid 
WHOIS data should be a criteria to complete registration of a domain name."
And, like Steve and others in the BC, I fully support the importance of 
referencing the importance of undertaking the WHOIS studies that continue to be 
discussed within the GNSO policy Council.
You might add in a sentence to 6. "Undertaking these long awaited studies will 
significantly contribute to the fact based understanding of all ICANN 
stakeholders.   The BC believes that such fact based research will help to 
inform the further consideration of WHOIS policy."  

Date: Tue, 13 Apr 2010 14:35:46 -0400
Subject: Re: [bc-gnso] Draft Comments on ICANN's Study of the Accuracy of the 
WHOIS Registrant Contact Information
From: sdelbianco@xxxxxxxxxxxxx
To: skawaguchi@xxxxxxxxxxxx; bc-gnso@xxxxxxxxx





Re: [bc-gnso] Draft Comments on ICANN's Study of the Accuracy of the WHOIS 
Registrant Contact Information


Susan — if you’re accepting any additional edits at this point, I wanted to 
offer some text that could strengthen our hand in getting funding for 
additional Whois studies.   Two weeks ago I prepared arguments favoring 
studies, and here are 2 edits that fit nicely with the Recommendations at the 
end of your comments:



5.  Continue studying the accuracy of the WHOIS.  ICANN should set higher 
standards for accurate Whois data for registrants.   After all, registrars 
manage to gather credit card information that’s sufficiently accurate to ensure 
they are paid by registrants.   Let’s find ways to ensure that registrars apply 
the same diligence in collecting and validating public Whois data.



6.  Fund additional WHOIS studies requested by Council for which staff is 
prepared to proceed.  The Misuse and Registrant ID studies are likely to 
generate data that would affect policy decisions and compliance work, 
especially with so many new TLD operators coming online next year.   These 
studies will help satisfy the Affirmation of Commitments (9.3.1), which 
requires ICANN to review the extent to which WHOIS “meets the legitimate needs 
of law enforcement and promotes consumer trust”.  Finally, we will want to have 
these study results on hand so they can be compared with study results after 
new TLDs are operating for one year, as required by the Affirmation of 
Commitments item 9.3 





On 4/9/10 8:35 PM, "Susan Kawaguchi" <skawaguchi@xxxxxxxxxxxx> wrote:



Hello All, 

 

Attached please find draft comments on the  WHOIS Accuracy Study.   

Comments are due on April 15th.  Please send me your comments, revisions or 
concerns prior to the 15th. 

 

Thanks Steve for your help. 

 

Susan Kawaguchi

Domain Name Manager



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Steve DelBianco

Executive Director

NetChoice

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