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WHOIS privacy

  • To: comments-ppsai-initial-05may15@xxxxxxxxx
  • Subject: WHOIS privacy
  • From: Deborah Taylor-Pearce <dtp@xxxxxxxxxxxxxxxxxxx>
  • Date: Fri, 26 Jun 2015 14:16:07 -0700


Dear ICANN --

Regarding the proposed rules governing companies that provide WHOIS privacy services (as set forth in the Privacy and Policy Services Accreditation Issues Policy document):

I am an independent scholar who has registered several dot-com websites, the first of which launched in 2004. All are experimental scholarly hybrids which embrace what has been called the "emerging Wild West in academic publishing."

As a pioneering content creator in this Wild-West netscape, I am always on the lookout for new business models that might help defray the exorbitant costs of doing and publishing post-doctoral, archival research.

In order to avoid potential conflicts of interest, protect the integrity of my scholarship, and maintain creative control over my intellectual property, I do not accept advertising or seek crowdfunding or other investors, but I *do* solicit donations, and may one day sell swag to make ends meet. To this extent, my scholarly websites are values-driven (rather than profit-driven) commercial enterprises -- in many ways, "more NON-PROFIT than many not-for-profits" (to quote one of my favorite arts organizations, yet another struggling social business).

Preferring to research, write, design, and code, I don't have time to engage in aggressive marketing campaigns, and the few donations I receive from appreciative vsitors to my websites don't even begin to pay the bills.

And yet, because of this modest entrepreneurial activity, it is now proposed that I -- a "sole proprietor," who gives away my intellectual property -- be treated as though I were Wal-Mart or Citibank or part of the thriving Big Commerce juggernaut on the Web. All of these dot-com entities have corporate IT departments and employees who are paid to be WHOIS registrants and interact with the public using corporate addresses and phone numbers which shield them personally from the threats of complainants.

I have no such protective bureaucracy in place.

My dot-com identity is inseparable from my personal identity, and while I agree that both ought to be accountable to their publics, I also believe that both should be able to control public access to confidential information. But under the new rule for privacy providers that ICANN is considering, the human person will end up with fewer rights to privacy and due process than the corporate person.

I have been using a WHOIS privacy service since March 2006, when I was first contacted by a stalker who accessed my personal contact data from the WHOIS database. Clearly, no proxy registration service can guarantee my online privacy 100%, but such a service is indispensable in protecting website owners like me from harassment, intimidation and identity theft. After so many years running widely-visited scholarly websites with an international following, I have had to become a zealous defender of my personal data. I not only rely on a WHOIS protection service for this, but I also refuse to participate in social media, in order that I can keep my private life private and, for the most part, off-line. This frees me to speak out on controversial issues -- such as gun rights, having recently produced a digital edition of the first debate over gun control in America, printed in 1684, for one of my dot-com websites -- which make me a target for all manner of disgruntled individuals trolling the Internet.

After years of prudently practicing safe computing, I am alarmed to learn that special interests, seeking unrestricted access to domain holders of websites even vaguely associated with "commercial activity," want to out me to the world ... and damn the consequences.

This should not be allowed.

I urge you to maintain the *status quo*, whereby my confidential information is protected by a WHOIS privacy service and can not be revealed to others, whatever their interests in me, without a court order.

Thank you.

Deborah Taylor-Pearce, PhD
Independent Scholar and Communications Research & Design Consultant


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