WHOIS privacy and “commercial purpose”

[Adam Langley <agl@xxxxxxxxxxxxxxxxxx>]

Dear Sirs,


As much as we would like it to be otherwise, the Internet doesn't always
bring out the best in humanity. The downside of being connected to everyone
is that “everyone” includes some very unpleasant individuals.

Even without considering the topic of political oppression, interacting on
the Internet risks SWATting[1] and death threats[2], amongst much else. The
majority of these incidents appear to be targeted at women and minorities.

While the intent behind the suggestion that “domains used for online
financial transactions for commercial purpose should be ineligible for
privacy and proxy registrations” might be sound, I can imagine little
benefit. On the other hand, I've no confidence that a sufficiently precise
definition of these sites could be crafted that doesn't result in major
problems.

DDoS attacks against sites are quite common. Does having a tip-jar on the
site to help cover the costs of these attacks count as commercial purpose?
As I'm sure members of ICANN are aware, even a brief lapse in WHOIS privacy
will be recorded in numerous databases so any disagreement about this would
be moot—as soon as the privacy registration is dropped, personal
information has already been disclosed forever.

Corporate entities are already recorded in state registries and I don't see
any way in which the benefits of publishing them in WHOIS comes close to
justifying the costs.


Yours faithfully,


Adam Langley


[1] https://en.wikipedia.org/wiki/Swatting
[2]
http://www.sltrib.com/sltrib/news/58528113-78/sarkeesian-threats-threat-usu.html.csp
[3] http://krebsonsecurity.com/category/ddos-for-hire/