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  • To: comments-ppsai-initial-05may15@xxxxxxxxx
  • Subject: comment
  • From: Kat Walsh <kat@xxxxxxxxxxxxxxxx>
  • Date: Tue, 7 Jul 2015 17:57:27 -0700

I'm writing in support of privacy and proxy services for WHOIS data.

I have used privacy services for my website for the past several
years. Both my partner and I are semi-public figures online and are
protective of our personal privacy. I have been harassed and
threatened (including by people in my area) for things I have written
online, and many of these people use publication of personal
information as a way of threatening targets. There are many ways to
contact me, as their are for many other users of such services, and I
do not hide from good-faith efforts to resolve disputes. (Those who
have an economic interst in evading responsibility can already invest
a great deal in becoming unfindable even if they must use "real" data
in WHOIS.) But if my home address is exposed to anyone who wishes to
see it, I would be at risk by having my own site. I am lucky: I can
afford to have a post office box, but this has not always been true.

It is not reasonable to suggest that people who are vulnerable to this
sort of attack should not register websites: in fact, many register
their own sites because they do not entrust their privacy to third
parties who has been shown to be irresponsible with user data, or
because they have things to say that are not within the scope of
mainstream platforms. Minority groups and viewpoints need independent
places to express themselves, and those are most likely to be targeted
with exposure or personal data.

The commercial or noncommercial status of speakers should be
irrelevant: it is not a useful distinction to draw. Large charities or
causes may be "noncommercial" but have millions of dollars at their
disposal and infrastructure to handle complaints without directing
correspondence personally to any individual. But a small home-based
business may have no such infrastructure, and exposing its details
would also expose the personal information of its proprietor. (And
when you work for yourself as a freelancer--ever more common in this
market--can your online presence really ever be noncommercial?)

The internet is a way for so many of us to speak even though we may be
at risk, and has allowed for a diversity of voices. ICANN should not
be pressured into taking this away for a "solution" that will do
nothing to stop people acting in bad faith.

Thanks,
Kat Walsh


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