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Re: [gnso-raa-b] RE: RAA: topics in category #7: Whois

  • To: "Metalitz, Steven" <met@xxxxxxx>
  • Subject: Re: [gnso-raa-b] RE: RAA: topics in category #7: Whois
  • From: Holly Raiche <h.raiche@xxxxxxxxxxxxxxxx>
  • Date: Sat, 2 Jan 2010 18:14:57 +1100

HI Everyone

My responses on Topic 7

Kind regards

Holly Raiche
Executive Director,
Internet Society of Australia (ISOC-AU)
ed@xxxxxxxxxxxxxx
Mob: 0412 688 544
Ph: (02) 9436 2149

The Internet is For Everyone

On 31/12/2009, at 8:09 AM, Metalitz, Steven wrote:


RAA subteam B participants:

As discussed on our most recent call, in order to move our work forward, it was recommended that we launch discussion of some of the remaining categories in the compiled list of RAA amendment topics. (I am using the revised chart, posted earlier today and dated today, December 30.)

According to my notes, we have discussed topics 1-4 in our previous call. On topic 5 -- compliance -- I have, by a message posted earlier today, asked staff to provide their views on our next call on Tuesday, Jan. 5. I have just circulated a message regarding topic #6.

Here are some views put forward to get the discussion started on topic #7, recognizing that our role at this stage is primarily to organize and prioritize the topics proposed, rather than to delve too deeply into the details of the proposals made. (This does not preclude us from deciding, if we can, that one or another topic is simply out of scope or not appropriate for consideration with regard to RAA amendments.)

RE:     Topics in category #7

Category 7 includes a number of topics, all related in some way to Whois. In order to get the discussion started, I suggest that we put the following topics in the “higher priority” category: A: 7.1 (also 7.6): required registrar responses to reported inaccurate Whois data

This probably requires further elaboration. For example, are we suggesting that Registrars proactively check the accuracy of registrant's WHOIS data both on initial registration and subsequently, or act only when it comes to the notice of the registrar. And should there be a more detailed requirement that registrars give the offending registrant notice of the inaccuracy/ incompleteness of the data for a set time period, and the followed by termination of the registration. Also should re there separate provisions if the information is not complete (all information required under RAA 3.3.1.6-8) or only if it is inaccurate?
B:  7.2 and 7.3:  links to be provided by registrar
C:  7.7:  Whois Service Level Agreement


The following topics appear to me to be more far-reaching and may take more time to deal with:
D:  7.4 (additional data collection requirements)
E:  7.9 (validation of data collected from registrants)

see above
I have omitted from this list the following topics:
7.5:  not clear how this would be reflected in an RAA amendment

Agree. The recommendation -is very broad - i.e., data to 'law enforcement agencies' for 'prevention...." Both terms are very broad and generally, if there is a basis on which information is sought, courts/magistrates will grant a subpoena anyway
7.8: this topic more properly belongs in the Compliance topic (#5).
Reactions welcomed on the list….
Steve Metalitz













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