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Registrar Stakeholder Group Position Regarding The Draft Report on WHOIS Accuracy

  • To: "whois-accuracy-study@xxxxxxxxx" <whois-accuracy-study@xxxxxxxxx>
  • Subject: Registrar Stakeholder Group Position Regarding The Draft Report on WHOIS Accuracy
  • From: "Clarke D. Walton" <clarke.walton@xxxxxxxxxxxxxx>
  • Date: Fri, 16 Apr 2010 00:25:07 -0400

April 15, 2010

Registrar Stakeholder Group Position Regarding
The Draft Report on WHOIS Accuracy


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.


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.


The opinions expressed by the RrSG in this position paper should not be 
interpreted to reflect the individual opinion of any particular RrSG member.


[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
Description: RSG Position - Draft Report WHOIS Accuracy FINAL.pdf

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