Wyndham Worldwide comments on WHOIS proposals

["Crane, Susan" <Susan.Crane@xxxxxxxxxxxxxxxxxxxx>]

I am writing on behalf of Wyndham Worldwide Corporation, one of the
world's largest hospitality companies, and owner of such well-known
brands as WYNDHAM, RAMADA, DAYS INN, SUPER 8 MOTEL and HOWARD JOHNSON,
and on behalf of myself as a frequent Internet user and online consumer.
 
As both a consumer and brand representative, I urge the DNSO to adopt
Motion 2 of the three proposed WHOIS actions.  Elimination of the
current WHOIS system, or its restriction to an Operational Point of
Contact, would negatively impact both brand owners and the general
public by removing yet another level of accountability for online
conduct.
 
As a corporation, Wyndham relies on ready access to WHOIS data in
several distinct ways.  Most obviously, we use WHOIS data to identify
and communicate with entities that have registered domain names which
incorporate one of our many brands as a tool in our online brand
enforcement efforts  Such efforts would become considerably more time
consuming, expensive and ineffective if we could not readily identify
the owner of a site.  The increasing proliferation of unauthorized
websites associated with domains that contain branded terms results in
consumer confusion and potential criminal activities, thereby lessening
the public trust in the online marketplace.  
 
In addition, Wyndham uses WHOIS data to identify domain names registered
on behalf of Wyndham by employees and agencies (such as advertising
firms) who are unaware of company policy regarding centralized domain
registration.  Without such information, we would have no way to know
whether such domains belonged to us or to unauthorized third parties.
 
As a consumer, I frequently look at WHOIS data of websites to help
determine whether a particular site appears legitimate and trustworthy.
I know that other consumers do the same, because I often receive email
from Wyndham's consumers questioning our association with particular
sites, and identifying the WHOIS information as one reason they were
unsure.  In this era of growing concern over the perceived threat of
online identity theft and related frauds, any step that diminishes
transparency in the online marketplace is likely to have a negative
impact for consumers and for all companies that engage in ecommerce.
 
For these reasons, I strongly urge the GNSO to undertake a far more
substantive analysis of the uses and abuses of WHOIS data before making
any changes to the status quo.  
 
Sincerely, 
 
Susan L. Crane
Group Vice President, Intellectual Property
Wyndham Worldwide Corporation
7 Sylvan Way
Parsippany, New Jersey 07054
 
phone - 1.973.753.6455
fax - 1.973.753.6620
 
PLEASE NOTE THAT MY STREET ADDRESS HAS CHANGED FROM 1 SYLVAN WAY TO 7
SYLVAN WAY.
 

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