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WHOIS Privacy Rule Changes

  • To: comments-ppsai-initial-05may15@xxxxxxxxx
  • Subject: WHOIS Privacy Rule Changes
  • From: Black Glance <blackglances@xxxxxxxxx>
  • Date: Wed, 24 Jun 2015 13:14:55 -0700

Good afternoon,

I'm writing today with great hesitation. It's my understanding that these
comments will be shared online as part of the consultation process, and
I've lived enough of my life online that I've come to understand that women
who speak out -- particularly about sensitive topics like harassment --
tend to be doing little more than inviting trouble. I don't want to bring
that down on myself, but honestly, from what I've seen of the new rule
changes I don't think I have a choice.

I am not comfortable with my personal information being made available
online. I am careful to use privacy safeguards as they currently exist, but
if that protection was removed I can guarantee that my ability to speak
freely online would be encumbered. I don't bully and I don't harass, but
I'm opinionated, and I've seen more than my share of similarly opinionated
women stalked, harassed, doxxed (i.e., their personal information made
publicly available) and even swatted (i.e., a SWAT team is called to raid a
victim's home based on a fake report). This is a matter of personal safety
for me and for many, many others.

I've also been told that one permutation of the rule changes could mean
releasing personal information to anyone complaining about trademark or
copyright infringement. If that's enacted, what steps are being taken to
protect that service's misuse at the hands of trolls, stalkers, or worse?
And what's the reasoning behind making that information available without a
court order? Every WHOIS privacy guard I've used has provided a masked
e-mail address to allow communication between complainants and the owners
of protected sites. If a lawyer wants to get in touch with an offending
webmaster, they can.

I'm sure someone somewhere has suggested that making that information
available to anyone who asks, as long as they can claim a trademark
violation has taken place, reduces the financial burden on the claimants,
and that may be true. But if that's the case, and the claimants cannot
afford to get a court order to compel the release of a webmaster's personal
information, then they can't afford to conduct a trademark violation case,
either.

So where does that leave us? It leaves with a system that forces vulnerable
users to make their personal information (including home addresses, in some
cases) available online for all to see. If there's an upside here, I just
don't see it.

Yours,

Elizabeth P.


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