Public Comment on the proposed changes in Who Is
Sirs, I am an at home user of the Internet and I am horrified and appalled that ICANN is proposing to allow Internet registrars to keep their identity private. There is no valid reason for such in my opinion. Registration with ICANN and placing a domain on the Internet is not a God given right, rather instead it is merely a commercial privilege. The ICANN should maintain the existing contractual requirements and if a potential customer or registrar is not able to meet the contract, then they should not be offered registration. If ICANN holds firm to the concept of full disclosure as a mandatory requirement for registration, the varied local or national laws prohibiting such will change as the economic feedback of "denied access" reaches the appropriate legislators. Instead of petitioning ICANN to allow a change in policy, those aggrieved by their local or national laws should be petitioning for local or national changes to allow them to declare themselves. That they are not doing so, is in and of itself a possible indicator of nefarious intent. There are many sleazy or illegal business opportunities that emerge when finding out someone's identity in a timely becomes difficult, burdensome, or time consuming. The first issue that arises is the chilling effect this proposed rule change will have on Internet credit card purchases and similar commerce. Here in the US a consumer has 30 days to dispute or cancel a transaction. If I log on to a website saying it is owned by (for example) "Joe Schmidt, Inc" and become interested in purchasing a product offered there, before laying my money down, I check the who is and affirm the identity and location of the web site. If I can not do this, then the transaction becomes very risky on my part. That it is proposed that even if I discover fraud two weeks after I submit the transaction, I can not readily discover the identity of the other party until after I first file in local court for a subpoena to ICANN for the records of the registrar, and then wait 30 days (during which time the other party skips town with the money they have fleeced) smacks of co-conspiracy. A second issue that arises from the proposed "who is" rule change is that of identifying the originators of Spam email (defined in this communication as email containing unsolicited commercial offers from parties no prior business relationship exists). Sending, or causing the sending of Spam email is a crime punishable by fine and imprisonment in Virginia, USA. This law was hotly debated publicly and then passed by a vote of the legislation. As I receive a hundred or so a day of these myself, I spend some time in helping to identify for prosecution those who send such unwanted spam emails, and such successful identification is done by using the "who is" on the varied IP numbers found in the email headers and within the varied local ISP databanks. Again, intentionally changing the "who is" rules to allow persons and companies participating in the Spam process to more effectively shield themselves from quick identification and quick prosecution smacks of co-conspiracy and again raises questions about the motives of those seeking such rule changes. It should be noted that the comment period for this proposed rule change is either way to short, or else ICANN has deliberately designed the process to put out the invitation for public comment to be of such a fashion that the average Internet user would never learn of the solicitation for comment. I appreciate the opportunity to supply an input. Today is the last day for such comment and it is only today that I learned of the solicitation. I considered myself well read and make daily visits to the science and technology news sites found on MSNBC, Reuters and CNN and no mention of this rules change proposal that would impact on tens of millions of consumers was found there. I will not divulge the party that sent me an email advising of the proposed change in rules as I fear that if I do so, I might not learn of the next proposed rule change in a timely fashion. I can be reached at superc@xxxxxxxxxxxxxxx Thanks Kenneth Coney |