Registrar Stakeholder Group Position Regarding The Draft Report on WHOIS Accuracy
April 15, 2010
Registrar Stakeholder Group Position Regarding
The Draft Report on WHOIS Accuracy
BACKGROUND
In March 2010, the Registrar Stakeholder Group ("RrSG") was asked to provide
feedback regarding the Draft Report on WHOIS Accuracy ("WHOIS Accuracy
Report"). This position paper captures the overall sentiment expressed by the
RrSG members who provided feedback about this matter. Due to time constraints,
however, no formal vote regarding this position paper was taken.
RrSG POSITION
The RrSG is troubled by the methodology employed by the National Opinion
Research Center ("NORC") in its recently published WHOIS Accuracy Report. The
RrSG agrees in part, however, with NORC's ultimate conclusion that greater
attempts to measure or improve WHOIS accuracy will result in commensurate
increases in cost to registrants.
Regarding NORC's methodology, The RrSG is concerned that the WHOIS Accuracy
Report established its "deliverability of the mailing address" criteria based
on the address model of the United States Postal Service, which calls for a
street or physical address among other data. RrSG members note that many
international addresses fail to satisfy this criteria. For example, RrSG
members note there are no postal codes in most geographic areas of Ireland and
that it is not unusual for an Ireland mailing address to consist of only the
name, town, and county of the addressee. It is clear that international
mailing addresses differ from mailing addresses in the United States and the
WHOIS Accuracy Report fails to account for these worldwide variations. ICANN
must be cognizant of the international nature of domain names when it
commissions studies examining data such as addresses or telephone numbers as
these international variations are likely to lead to errors.
The RrSG notes that the WHOIS Accuracy Report identified only 7.8% of WHOIS
records containing a full failure of WHOIS data accuracy. The WHOIS Accuracy
Report did not examine, however, each domain name's expiration or deletion
status. The RrSG suggests that a significant portion of this 7.8% full failure
rate may be attributed to domain names that were near expiration or were
intended to be deleted by their respective registrants. In such cases the
likelihood that the domain name registrant maintained accurate WHOIS data is
probably decreased, which may account for a portion of the 7.8% full failure
rate. The RrSG also notes that approximately 80% of the registrants studied
were located or accurately provided deliverable addresses which indicates to
the RrSG that WHOIS data accuracy issues articulated by other ICANN community
stakeholders are exaggerated.
With respect to barriers to maintenance of accurate data, the RrSG agrees with
the conclusions of the WHOIS Accuracy Report that state, "there would be costs
involved in [maintaining accurate WHOIS data] which ultimately would need to be
borne by the registrants," "the cost of ensuring accuracy will escalate with
the level of accuracy sought, and ultimately the cost of increased accuracy
would be passed through to the registrants in the fees they pay to register a
domain." These potential costs are substantial and should not be
underestimated by ICANN.
RrSG members draw analogies to the United States census, which attempts to
gather demographic data including names, addresses and telephone numbers for
more than 300MM Americans. The United States conducts its census study only
once every 10 years and the 2010 census study is projected to cost a staggering
$11 billion U.S. dollars.[1]
With more than 100MM gTLDs currently registered, the RrSG suggests that
reliably measuring the accuracy of WHOIS data is analogous to undertaking a
worldwide census of domain name registrants. This is a financially and
technically unfeasible proposition. Equally as troubling in terms of both cost
and reliability are proposals that call for implementing systems to verify the
accuracy of WHOIS data. In the RrSG's view, the only acceptable proposal to
verify the accuracy of WHOIS data is a system that is flawless and could not
potentially interfere with bona fide domain name registrants. No such system
currently exists nor is such a system likely feasible. To this end, it should
be recognized that even well established and rigorous offline systems that
attempt to verify contact information, such as processes for automobile driver
licensing, are subject to inaccuracies.
In summary, effectively measuring WHOIS accuracy or verifying WHOIS data are
extraordinarily complex and costly tasks. As the WHOIS Accuracy Report
correctly indicates, the cost of increased accuracy would ultimately be passed
through to registrants in the fees they pay to register a domain name.
Additional registration fees may negatively impact financial accessibility to
domain names for registrants, ultimately resulting in fewer domain name
registrations or underutilization of registrations. A decrease in domain
registrations results in negative economic consequences for domain name
registrars and registries, thereby harming the health and growth of the entire
ICANN community.
The RrSG submits that an appropriate mechanism already exists to manage
incomplete or inaccurate WHOIS data. The WHOIS Data Problem Report System
("WDPRS") was implemented in 2002 and recently revised in 2008. In 2008 alone
more than 200,000 reports were filed which enabled ICANN to address concerns
including inaccurate WHOIS data. The RrSG strongly prefers that ICANN focus
its resources on improving and publicizing awareness of the WDPRS rather than
commissioning expensive research into further WHOIS accuracy studies which lead
to unrealistic and cost prohibitive conclusions.
CONCLUSION
The opinions expressed by the RrSG in this position paper should not be
interpreted to reflect the individual opinion of any particular RrSG member.
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[1] See Significant Problems of Critical Automation Program Contribute to Risks
Facing 2010 Census, United States Govt. Accountability Office, available at
http://www.gao.gov/new.items/d08550t.pdf (published March 5, 2008).
Attachment:
RSG Position - Draft Report WHOIS Accuracy FINAL.pdf |