Comments related to WHOIS final report

[<KPetrich@xxxxxxxxxxxxxx>]

We would like to weigh in on the proposed changes to WHOIS.  We are
intellectual property attorneys that have been practicing for
approximately 16 and 15 years, respectively. We use WHOIS information
almost daily in our practice.  It is critical that we can ascertain a
domain name owner and information about such owner in our evaluation of
client's trademark rights.  Further, as there are commerce implications
to the use of domain names, there is always a risk that the public at
large will be deceived or confused, that the rights of trademark-owners
will be harmed, or that unfair competitive acts will be engaged in. It
is critical that the general public have access to the accurate identity
of the owner of any given domain name or an authorized agent who has
such owner's power of attorney and can receive and respond to legal
correspondence for such owner. Such information should be available
through public resources, just as are the names and contact information
for licensed and registered commercial businesses and their owners--and
the names and contact information for the owners of registered
trademarks and copyrights.  As such, and for the reasons well stated by
the Intellectual Property Constituency ("IPC") in Section 13.3 of the
Final Report, we, too, voice our concern and objections regarding the
Task Force's proposal.   
 
Thank you for your consideration.
Robert C. Cumbow, Attorney, e-mail: RCumbow@xxxxxxxxxxxxxx

Kathleen T. Petrich, Attorney, e-mail: KPetrich@xxxxxxxxxxxxxx
<mailto:KPetrich@xxxxxxxxxxxxxx>  

Graham & Dunn PC 
Pier 70 
2801 Alaskan Way, Suite 300 
Seattle, WA 98121-1128 
T: 206.624.8300 (main reception) 
F: 206.340.9599 
Web site: www.grahamdunn.com <http://www.grahamdunn.com/>  

 
 

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