[gnso-dow123] ALAC position on Recommendation 1

["Maria Farrell" <maria.farrell@xxxxxxxxx>]

Dear all,
 
Below is the ALAC position on Recommendation 1 on improving notification and
consent.  It wasn't submitted to the recent public comments forum and so
hasn't been included in the summary of comments on the Final Task Force
Report. However, I think it is an important part of the record of views on
this recommendation and I would like to add it to the Final Task Force
Report. 
 
I suggest including the ALAC position in an amended section 1.2 of the
document entitled 'Summary of public comments on the Final Task Force Report
(2005)'. It can be footnoted to say it was officially received after the
deadline for public comments.  I would also suggest asking ALAC to send the
position to the public comments forum so that the forum will be historically
complete for future reference.
 
I don't think this is a substantive change to the report that would require
further discussion on a task force call.  But please let me know if you have
an objection to this inclusion by end of today, Thursday May 25th at the
latest. 
 
Many thanks, Maria
 
 

ALAC position on recommendation on improving notification and consent for
the

use of contact data in the Whois system. 

The At Large Advisory Committee ("ALAC") appreciates the opportunity

to review and comment on the latest work of the Generic Names Supporting

Organization on the subject of improving notification and consent for the

use of contact data in the Whois system. The ALAC supports the concept of

mandatory disclosure that underlies these recommendations but believes

that the following two changes would bring clarity to the proposed policy

and enhance the registrant's experience:

 

1. In Recommendation No. 1, the phrase "availability and" does not appear

to add anything to the policy and, as phrased, potentially creates

confusion. Data that is accessible by third-parties is also "available."

The ALAC recommends that the GNSO delete the words "availability and" from

Recommendation No. 1.

 

2. In Recommendation No. 2, the recommends deleting the last sentence

altogether ("The wording of the notice provided by registrars should, to

the extent feasible, be uniform"). To the contrary, the ALAC believes that

registrants would be better served by having registrars make the

disclosure in their own way, in their own languages, using whatever

phrases they deem proper for their respective customer bases.

 

The ALAC applauds the GNSO and its task forces for making progress

on such difficult policy issues and looks forward to participating in and

commenting upon future policy initiatives.