Re: [gnso-dow123] For your review: Revised version of preliminary task force report on Whois services

[Ross Rader <ross@xxxxxxxxxx>]

Marilyn Cade wrote:

> However, I don't believe that this is supportable over 800 registrars. Some
> form of standardized procedures will undoubtedly be needed to bring
> certainty and predictability to registrants, irregardless of the interests
> of registrars to develop kinds of services in this area. 

Again, I'm going to ask what the basis for this contention is? Your 
personal conjecture isn't sufficient to turn "belief" into fact.

If you have data that you'd like to share with the TF on this point, I'd 
encourage you to do so. I'd also like you better understand the basis 
for your implication that the basis for the registrar policy position is 
to support the development of new services. This is simply not the case.

Please also note that the number of operational registrars has been 
relatively stable at around the 200 mark and that the remainder of the 
registrars in the 800 that you quote are controlled by one or two 
entities involved in the aftermarket game. They do not come into play in 
consideration of this policy because they do not have real registrants 
to speak of.

Finally, I think your conjecture confuses the needs of registrants with 
the needs of the intellectual property interests that you and your 
associates represent in this discussion.

I would really urge you to reconsider the argument that you are putting 
forward considering that you are describing a large part of the 
operational requirements that registrars already deal with in their day 
to day operations. We are not seeking to change our role as the 
maintainer of registrant data in the registration process. The 
implications you are making are completely unfounded (but entirely 
predictable unfortunately).

Ross Rader