[bc-gnso] FOR REVIEW: Latest draft of BC comments on Expert Working Group (EWG) for directory services (Whois)

[Steve DelBianco <sdelbianco@xxxxxxxxxxxxx>]

As a follow-up to Thursday's BC call, here's a new draft for member review.

First thing I did was re-read the EWG report on which we are commenting. 
(link<http://www.icann.org/en/groups/other/gtld-directory-services/initial-report-24jun13-en.pdf>)
  It's also helpful to review FAQs published by the EWG 
(link<http://www.icann.org/en/groups/other/gtld-directory-services/faqs>)

Second thing I did was review prior BC positions on this, starting with our 
Jul-2011 "Response to WHOIS Policy Review Team Discussion Paper" 
(link<http://www.bizconst.org/Positions-Statements/BC_on_WHOIS_Review_Questions.pdf>)
 where the BC said:  "ICANN should also consider mechanisms to create and 
maintain a centralized WHOIS database."

Also see Jun-2012 BC comment on WHOIS Affirmation Review 
(link<http://www.bizconst.org/Positions-Statements/BC%20on%20WHOIS%20RT%20Final%20Report.pdf>),
 where we endorsed privacy/proxy obligations:
• Adopting agreed standardized relay and reveal processes and timeframes
• Conducting periodic due diligence checks on customer contact information;
• Providing clear and unambiguous guidance on the rights and responsibilities 
of registered name holders, and how those should be managed in the Privacy / 
Proxy environment.

And see our May-2013 comments on the new RAA 
(link<http://www.bizconst.org/Positions-Statements/BC%20Comment%20on%20final%202013%20RAA%20%5BFINAL%5D.pdf>),
 where we proposed Relay and Reveal obligations and timelines for privacy/proxy 
services.

Then I started with our 9-Aug draft comments and added discussion from 29-Aug 
BC member call.

Attached is my 2-Sep draft, plus a redline comparing with the previous draft 
distributed (9-Aug).

Please REPLY ALL with objections or comments before Thursday 5-Sep so we can 
meet the EWG deadline of 6-Sep.

Looking forward to an informed and respectful discussions, so we can get our 
thoughts to the EWG while they are working on their final report for October 
publication.

--
Steve DelBianco
Executive Director
NetChoice
http://www.NetChoice.org and http://blog.netchoice.org
+1.202.420.7482

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Attachment: Whois Directory Service - BC Comments 2-Sep-2013 [Steve].doc
Description: Whois Directory Service - BC Comments 2-Sep-2013 [Steve].doc

Attachment: Redline from 9-Aug to 2-Sep versions.docx
Description: Redline from 9-Aug to 2-Sep versions.docx