Allow continued domain privacy

[Chris Gebhardt <chris@xxxxxxxxxxx>]

Dear members of the Working Group,
I'm pleased to offer comments for your consideration regarding whois 
privacy.   We have provided website design and hosting, as well as other 
services, since 1996.   Our client list includes Fortune 100 companies, 
"mom and pop" operations and everything in-between.
We utilize privacy services for a number of our clients who prefer their 
domain registration not reflect personal contact information.
One of the great things brought about by the mass adoption of the 
Internet as a platform for communication and commerce is the way that 
the playing field has been leveled for big operators and small 
independents alike.
The objection to whois privacy appears to center around an inability to 
contact the registrant in the event it is necessary to communicate with 
the registrant for a given reason.   This is simply not the case, since 
accredited domain privacy providers will always forward pertinent 
messages to the registrant by means of systems already in place.
The Whois Accuracy Program Specification of ICANN's 2013 Registrar 
Accreditation Agreement (RAA) already calls for the verified accuracy of 
domain registration information.  Domain registration providers are 
already ensuring that valid contact information exists for domains in 
their registry.  It is therefore held that when a domain registration 
provider has verified contact information, and is then called to provide 
privacy and forwarding services for a domain, a reasonable method to 
make contact with a domain holder already exists.
Whois privacy can play an important role here by providing the same 
protection afforded to large corporations who can afford to mask their 
domain ownership under holding companies, lawyers, post office boxes and 
other means of obfuscation.  While there will always be bad actors, it 
does not make sense to throw out an entire system of privacy protection 
that is used for legitimate purposes by responsible domain holders.   To 
do so would unjustly penalize small operators and runs counter to the 
long-held principals of Internet culture.
Eliminating domain privacy as it currently exists will only serve to 
endanger free speech, discourage competition and inhibit innovation. 
Free speech, healthy competition and innovation.  Those principals have 
always been the foundation of Internet commerce.
Throughout the course of my 20-year career as a professional Internet 
service provider, I have always taken great personal pride to play a 
part in changing and enhancing the ways people work, play and interact 
with each other.
The continued availability of domain privacy and its ability to protect 
entrepreneurs, small business operators, non-profits and others should 
be considered crucial.  I urge the Working Group to thoughtfully 
consider the negative impact of implementing changes to domain privacy 
rules and recommend against adoption of rules that would be onerous to 
domain registration providers and registrants alike.
Sincerely,
--
Chris Gebhardt, President
VIRTBIZ Internet Services
chris@xxxxxxxxxxx | (972) 485-4125