Comments of Coalition for Online Accountability
The Coalition for Online Accountability (COA) strongly
opposes Telnic's proposal to radically curtail the publicly accessible
registry Whois service it promised to provide when it concluded its
contract with ICANN 13 months ago, for the following reasons, among
others:
1. Telnic's allegations of incompatibility between Telnic's Whois
obligations and applicable law are too ambiguous to justify
consideration of its proposed amendment on that ground. If there were
any concrete evidence of any such incompatibility, the issue ought to be
addressed under ICANN's Board-adopted policy for handling such
conflicts, rather than as a new registry service.
2. Approval of Telnic's proposal would have serious detrimental
impacts upon security and stability, would make it impossible for Telnic
to fulfill other aspects of its contract, and could create conflicts
with other laws and with ICANN's commitments under the Joint Partnership
Agreement with the US government.
3. The Board's approval of a change in Whois policy for .name
specifically ruled out use of that decision as a precedent in future
cases. Furthermore, contrary to Telnic's assertions, its proposal bears
little resemblance to that approved by the Board with respect to .name,
and it would far more comprehensively suppress access to Whois data for
a host of legitimate purposes supported by public policy.
.
Please see the detailed comments of COA attached.
Steven J. Metalitz
Counsel, Coalition for Online Accountability
www.onlineaccountability.net
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