comments

[Bob Bruen <bruen@xxxxxxxxxxxx>]

Hi,

I am concerned about section 3.1.4  Voluntary Adoption through Promotion 
and Incentives
These two statements show a low level of understanding of the current 
situation:
1) The users of Whois services get access to a free service, and it is
possible to run high volume queries in various ways to mine the data.

2) There is a fee to get bulk access to Registration Data on a per
registrar basis - but it is rarely used these days due to (1) above.

First, users do get free access, but almost all of the registrars warn 
against using high volume, automated queries. Secondly, if you do run 
these queries, you will be switched to the thin record, instead of getting 
the thick record. GoDaddy forces you to go to a web page to prevent high 
volume queries.
The registrars generally go out of their way to make it difficult to 
obtain WI data, happily spending resources they say they can't afford.
KnujOn published a study on bulk access to whois data last year. There are 
several reasons why people do not use it. The first is that most 
registrars did not know what it was when I asked them about it. Many 
refused to even provide a process, such as filling out a form to request 
it.
Once word got around that I was doing this, someone at ICANN told them to 
simply charge $10,000 dollars, most did just that.
Only ARIN actually provided their bulk whois data out of all the 
registrars.
The registrars have no incentive to provide whois data because they are 
well aware they at least half of the records are inaccurate and a large 
percentage of the records are for criminal activity. And yes, I have the 
data.
If this lack of understanding is going to be the basis for future 
decisions, I fear the situation will continue to get worse.
         Robert Bruen

--
Dr. Robert Bruen
http://coldrain.net
http://coldrain.net/bruen
+1.802.579.6288