- To: <WHOIS-COMMENTS-2007@xxxxxxxxx>
- Subject: Whois Proposal
- From: "Aimee Nolan" <Aimee.Nolan@xxxxxxxxxxxx>
- Date: Mon, 29 Oct 2007 15:58:43 -0500
In response to ICANN's proposed changes to access to the Whois Database, as a
representative of a major trademark/brand owner, we support adoption of Motion
2 as proposed by the GNSO Council and urge the Council to reject Motions 1 and
As a representative of a major brand owner charged with policing the company's
intellectual property, the Whois Database and the information it provides is
essential in policing and protecting the company's valuable intellectual
The Whois information helps to protect brand owners and the general public in
the following ways:
- identifies the owner of the domain name, which informs consumers and
trademark owners with information regarding whom they are dealing with
- gives the general public and brand owners alike a way to contact the
domain name owner to settle problems and/or obtain information from the owner
in a less costly manner than the structures proposed in Motions 1 or 3, or
having to file a legal action to obtain owner information
- can help brand owners determine if the domain name owner has
- helps brand owners determine if a domain name registrant has
registered other names owned by brand owners (i.e., cybersquatters)
- saves everyone time and money since no additional resources need to be
spent to investigate/discover who owns a particular website.
o If businesses have to spend considerable time and resources tracking
down domain name owners the cost is inevitably passed on to consumers,
resulting in higher costs for everyone.
o The same for law enforcement agencies. The additional cost and
resources needed to track down this information generally results in increased
taxes to pay for the additional resources needed.
- lets brand owners and law enforcement know in what jurisdiction an
action would need to be filed
Not only would brand owners be harmed by the Motions 1 and 3 as proposed by the
GNSO Council, by making it more time consuming, costly and possibly impossible
to protect their brands; the general public would be harmed much more by
increased phishing attacks, counterfeit goods and other unauthorized activities
that are being conducted online.
Therefore, we submit that ICANN should conduct a thorough study on the actual
uses of the Whois data and then propose a policy change that would take into
consideration any such legitimate uses.
Aimee M. Nolan
Senior Corporate Counsel
W.W. Grainger, Inc.
100 Grainger Parkway, B4.T56
Lake Forest, IL 60045-5201