Comments regarding the Policy

[PSI-USA Hostmaster <hostmaster@xxxxxxxxxxxx>]

Hello,

in general, the new POLICY was introduced although ICANN knews
beforehand that it contained flaws.


1. NO standardized WHOIS output for THIN Registry/Registrar.

A Solution could be:

ICANN and VeriSign works out a standard for the Registrar's
WHOIS (how com/net domains must be displayed in the whois),
at least every Registrar must present a standardized key/value
pair in his whois for every com/net domain for:

Admin-C-Email-Address:
Owner-C-Email-Address:

This makes it easy for every Registrar to parse this and
automize further processes. The current diversity (there are
up to 100 different WHOIS outputs) makes it impossible
for the industry to adopt hundreds of WHOIS schemes within
the next month. The implementation costs are from 10.000 USD
to 100.000 USD, we asked some programmers in the USA!
And it will take up to one year.

Further problems: Once, a Registrar is able to parse
hundreds of different whois outputs to find out the correct
Admin-C or Owner-C Email Address, there is NO GUARANTEE that
this will also work tomorrow. Since every Registrar is free
to change the output from this WHOIS server daily, it is not
possible to be up to date. I guess many Registrars will implement
a "dynamic whois output" for such fields to make it hard/impossible
to automize a process on the whois output. It's normal, no one want's
to lose domains. OTOS, no one could start many transfers if
a Registrar daily changes the fieldnames for their
output on a daily or constant basis.

Currently, there are Registrars that are making WHOIS-Roulette,
always display the output different to make it hard/impossible
to automize this.


2. Since for com/net domains the WHOIS of the Registrar is the
source for getting informations, there must be a POLICY for all
Registrars to allow queries for ALL other Registrars without any
exception! NSI, for example, limits their WHOIS. It's very hard
to start hundreds of transfers if their WHOIS always blocks.

There should be a Registrar-Wide WHITELIST for all Registrars,
maintained by ICANN.


3. Summary

The proposed use of FOA's via mail could be compromised
by everyone. Once, the spam filters treat the FOA's as SPAM,
the industry stops.

Since there is no standard how Registrars have to present
their data's in the WHOIS, it is technically not possible to
automize further processes. The implementation costs for such
software are not manageable.



Best regards

Curd Bems

--
With best regards,
TEAM PSI-USA / Hostmaster
_______________________________________________
PSI-USA Inc., DNS Service Center (Hostmaster)
Maximilianstrasse 6, 93047 Regensburg, Germany
Curd Bems, hostmaster@xxxxxxxxxxxx
Tel. +49 941 59559-235  Fax. +49 941 59559-457