Privacy Rights

[Ty Carter <tmcarter@xxxxxxxxxxxxx>]

To whom it may concern:

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 a small business owner that is on the technology forefront and I for one 
am HIGHLY offended that even the mere implication that an entity such as 
MARKMONITOR could even think it reasonable to demand that my private monetary 
transactions for an intellectual property transaction would have to be made 
public in the way that would basically undermine the very structure of a 
private contractual agreement for services between two parties, regardless of 
the nature of the transaction.

If I, as an agent first for my clients, and then a private individual wish to 
appoint and request agent / proxy services, via my registrar for my domain name 
purchases, then that is my right to do so. NO ONE other than law enforcement 
wielding a search warrant or other public govt agency, holding the same warrant 
should not have to divulge that customer information... This is done all the 
time in various transactions, including real estate and legal forms, such as a 
legally binding Power of Attorney, or agent in fact.

The spurious theft of service that has been attempted from companies like 
Domain Registry of America, even further suggest proxy hosting and the ability 
to weed out the wheat from the chaff is still needed.  I get weekly calls from 
clients or clients that are emailing me scanned forged or masked "legit" domain 
registry bills, some threatening to cut them off, and others luring the client 
into a deceptive ring of theft of service or impersonation.. because some of 
their transactional information is not maskable or proxied because of the very 
nature of the domain name that has been transacted for.

I want my domains private and if there is a need for contact, my registrar 
knows how to legitimately contact me...

Now... That brings to bear another issue...

Should you like to discuss this matter and my opinion further in detail, I 
would welcome any and all dialogue concerning this issue....



I would propose the following adoption of rulemaking....

I do think it is entirely reasonable to ensure the registrar has valid contact 
and account information for EVERY domain, even if the client wishes anonymous 
or proxied registration... but the registrar should be required to make annual 
or biannual contact with the domain owners to validate still current contact 
information.  If the registrar can not contact or does not receive a response 
within 90 days of initial contact to validate, and the clients domain it paid, 
then the registrar should, under their own discretion be placed in an 
"unverified" status and the domain name suspended when and only when contact 
can not be made.

Thank you for your patience in this matter,

Respectfully submitted, I am;

Ty Carter, President
Strategic Network Consultants, Inc.
524 East 9th Street
Washington, NC  27889
252-946-0351 .::. Office
252-402-5296 .::. Cell
Email:  tmcarter@xxxxxxxxxxxxx<mailto:tmcarter@xxxxxxxxxxxxx>

Visit us on the web at 
http://www.strategicconsultants.net<http://www.strategicconsultants.net/>
[cid:image001.png@01D0AF92.D21B87D0]