"InterContinental Hotels Group Comments"

[Ashley Stocks <astocks@xxxxxxxxxxxxxxx>]

        As the Global Head of Data Privacy of InterContinental  
Hotels Group, I write in support of motion 2 and in strong opposition  
to motions 1 and 3.

        InterContinental Hotels Group PLC of the United Kingdom is  
the world’s largest hotel company. We own, manage and franchise  
several of the world’s most famous global hotel brands, including  
InterContinental®, Holiday Inn®, Holiday Inn Express®, Crowne Plaza®,  
Staybridge Suites®, Candlewood Suites® and Hotel Indigo® – a total of  
over 3,600 hotels and 537,500 guest rooms in nearly 100 countries and  
territories around the world.

        Our customers booked more than $1 billion on our websites  
last year, and our Holiday Inn website was the most frequently  
visited hotel brand site in the world.  We depend on Whois to quickly  
identify and contact unauthorized domain name registrants and website  
operators.

        Our experience has shown that consumer protection is  
essential to sustain and promote Internet commerce transactions.  As  
part of that, consumers need access to Whois to verify who owns and  
operates a particular website.  In the interest of consumer  
protection, our businesses need access to the Whois database to  
protect the privacy and security of our customers to reduce the risk  
of online fraud, including identity theft.

        We cannot support any process that puts barriers in the way  
of going after bad actors on the Internet.  If the oPOC proposal were  
adopted, most of the data now in Whois could be cut off from public  
access, rendering most of the current public and business uses of  
Whois virtually impossible.  Reducing public access to Whois will  
have a seriously detrimental effect on our consumer protection  
efforts worldwide.

        It is critical that ICANN preserve and enhance access to  
Whois data for purposes of protecting consumers and fighting fraud.  
Further, there is clearly a need for ICANN to implement measures to  
enhance the accuracy of registrant information to prevent such  
abuses. There is a tremendous public interest value in a rich Whois  
data set with information on registrants and administrative contacts.

        Sincerely,


        Lynn Goodendorf

        Global Head of Data Privacy
        InterContinental Hotels Group