Comment Regarding Whois System
To the members of the GNSO Council and ICANN: Wal-Mart Stores, Inc ("Wal-Mart") strongly urges the GNSO to support Motion 2 and reject Motions 1 and 3, which are slated for vote by the GNSO on October 31, 2007. Wal-Mart regularly uses the Whois system to research and contact the registrants of infringing and fraudulent domain names to protect our customers from online scams and other illegal activity. Wal-Mart urges the GNSO to support Motion 2, advanced and supported by INTA's Internet Committee, which proposes a thorough study of the legitimate uses and the abuses of Whois data, before making a policy change that would alter the current structure of the Whois system relied upon by consumers, brand owners and law enforcement personnel to research and combat online fraud. In addition, Wal-Mart urges the GNSO to reject Motions 1 and 3. Motion 1 proposes a new "Operational Point of Contact" ("OPoC") but the legal responsibilities of the OPoC are undefined and the proposal limits the amount of publicly displayed domain name ownership information - the type of data regularly relied upon by consumers, law enforcement officials and brand owners to protect consumers and intellectual property rights on the Internet. Motion 3 proposes eliminating all contractual obligations that require registrars to display domain name ownership and contact details and effectively abolishes the entire Whois system for Generic-Top-Level domain names. Further, removing access to the Whois database could eliminate disincentives for abuse perpetrated over the Internet. We thank ICANN for the opportunity to provide this comment. Sincerely, Debra Y. Hughes, Esq. Assistant General Counsel Wal-Mart Stores, Inc. Debra Y. Hughes, Assistant General Counsel Phone: 479.277.1695 Fax: 479.277.5991 Wal-Mart Stores, Inc., 702 S.W. 8th Street (MS 0520) Bentonville, AR 72716-0520 debra.hughes@xxxxxxxxxxxxxxxx <<Picture (Metafile)>> This e-mail and any attachment are privileged and confidential. If you have received this e-mail in error, destroy it immediately.