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please reconsider this!
- To: <comments-ppsai-initial-05may15@xxxxxxxxx>
- Subject: please reconsider this!
- From: "Dmitry Kuzmenko" <morfizm@xxxxxxxxx>
- Date: Sat, 27 Jun 2015 19:00:06 -0700
Dear ICANN,
I've just learned from namecheap.com that you are going to implement a policy
restricting private WHOIS registrations.
I've tried to read the detailed proposal but it's too bureacratic language and
given I could only spend a few minutes I couldn't quickly grasp the idea, so I
have to trust what I learn from namecheap and news. They claim you're going to
require privacy proxies to require actual users to disclose their registration
(that includes names and addresses publicly). This should apply for small
business and not to personal sites, but I can easily imagine the line is very
blurry there (what if I have a personal site while making some money on ads?),
so it will probably apply to almost everyone.
First, this is ridiculous news and I am totally surprised you managed to sneak
in such a big thing on such a short notice that whois companies require to
resort to initiatives like that. I am watching tech news regularly and haven't
heard of this before. This is apparently a very big issue, similar to other big
issues such as Open Internet, that require adequate significant time for public
debate and response from privacy support groups before you can act on anything
like that. At least a year and may be multiple years. Please wake up and look
what you are doing. Who is pressuring you and urging you?
Second, I hope you understand that this initiative is against individual
privacy rights, and will expose individuals to personal risks. If a small
business owner gets killed as a result of you requiring him to publish his home
address, will you fill responsible for that? Will you have a bad night time
sleep? Think about that.
If it is trademark agencies who are pressuring you, think that you're trading
*personal safety* of people (think of me and you, think of your children) for
the conveniences of greedy businesses. In my opinion, it is totally
unacceptable and you should do best you can to further respect privacy and
strengthen privacy protections. I am not challenging the right of law
enforcement agencies to obtain contact information in case if they have a court
order - in my opinion that's okay. I am challenging the absurd initiative to
require to make contact info public - public is public for everyone, it will
not be public just for law enforcement and law entities, it will also be public
for all sorts criminals. It will also encourage greedy trademark and copyright
trolls to abuse people with threats instead of going through a fair legal
process.
Third, in engineering there is a practice called dogfooding. It means
test-driving new versions of software within your own employees before the
software get released, in order to get early feedback and ensure higher quality
of the product. Dogfood products are often raw and buggy, but that's the point
- to catch problems early and make them better before affecting the masses.
It's also possible to dogfood processes and policies. I think the policy like
yours really deserve dogfooding to let you better understand the impact.
Consider talking to your children and suggesting them to start a small business
website. For example, a commercial blog on regilious topics. Also tell them,
that as a part of the new policy you're working on, they will be required to
make their name and home address public. If you can convince your children to
do that, and you're feeling safe about them afterwards, that's a good start. I
am sure the ridiculousness of the policy would've been revealed quickly if you
did this at least as a thought exercise.
Please stop this initiative and reconsider!
Privacy of website owners should not be disclosed without a court order.
Thank you,
Dmitry.
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