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Summary/analysis of comments

  • To: <telnic-whois-proposal@xxxxxxxxx>
  • Subject: Summary/analysis of comments
  • From: "Kieren McCarthy" <kieren.mccarthy@xxxxxxxxx>
  • Date: Tue, 18 Dec 2007 07:59:01 -0800

Posted by Kieren McCarthy, General manager of public participation, ICANN




Summary of public comments for Telnic Whois contract change


November 2007






The company in charge of the new .tel registry, Telnic, proposed a change to
its contract regarding the "Whois" public provision of domain registrant
information. This was put out for public comment, subsequent to which the
company made significant alterations and resubmitted it.


The issue has arisen because Telnic is due to launch .tel soon and it wishes
to be fully in compliance with UK privacy law before it does so because it
is headquartered in the UK.


Under the revised proposal, Telnic will continue to publish full Whois
information for legal persons. Telnic will collect from registrars full
Whois information for natural persons, but only limited information will be
displayed. Requestors seeking full contact information for natural persons
may use a secure Special Access Service to obtain non-public data.


This public comment period was set up to allow for community feedback on the
revised contract change. In total, two relevant comments were received.


This analysis attempts to summarize the relevant comments from the online

Where possible and practical, individual comments have been attributed to
individuals or organizations by attaching initials to the comments.  A key
to the initials used can be found at the end.



General comments



One commenter felt that the existing Whois system should be adhered to in
order to most effectively deal with cybersquatting [PR]. The second
commenter felt that the modified proposal was greatly improved and with a
few "minor clarifications" could be granted approval by the ICANN Board



Prior consultation


The point was raised that a previous, similar registry contract changes with
respect to Whois had involved a larger degree of prior consultation [SM].



Special Access Service


It was argued that information acquired through the Special Access Service
(SAS) - where accepted requestors are granted access to non-public
registration information - should be allowed to be shared with others
outside the SAS system. Examples of lawyers and fraud investigators were
given [SM].


It was pointed out that the selection list for what would be seen as
legitimate requests for data through the SAS system has not been made
available [SM].


It was argued that allowing only five SAS requests per 24-hour period may be
too restrictive and argued that Telnic be allowed to change this figure in
future without having to put in a formal request to ICANN [SM].


It was not clear what Telnic would do with the information it gathered from
use of the SAS system [SM].





It was argued that Telnic's assertion that it needed to change the Whois
wording in order to be compliant with UK law was not sufficiently strongly
made to override the tradition of requiring people to follow a common Whois
approach [SM].


It was accepted that while Telnic proposed business model for .tel may be
sufficiently unique to grant it an exception to the common Whois rules,
ICANN should make that change contingent on Telnic maintaining that
particular model [SM].


It was suggested that ICANN reaffirm the need for Telnic to use
ICANN-accredited registrars for registering domains under .tel [SM].





PR       Paul Robinson

SM      Steven Metalitz, Coalition for Online Accountability / International
Trademark Association Whois Subcommittee  




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