ICANN Whois public comments

["Chris Hammond" <Chris.Hammond@xxxxxxxxx>]

Dear Sirs

The British Phonographic Industry Limited ("BPI") is the UK national
group for the International Federation of Phonographic Industries
("IFPI") and a member of the Internet Enforcement Group (see
www.ieg-uk.org).  Our members comprise over 300 record companies in the
United Kingdom.  Between them our members are responsible for the
production or distribution of the vast majority of sound recordings sold
and/or distributed legally within the United Kingdom.  The BPI is also
mandated to act on behalf of the members of Phonographic Performance
Limited ("PPL") and the Association of Independent Music Limited ("AIM")
and in this respect, to protect the rights in the sound recordings that
are owned or controlled by members of PPL and AIM, as well those that
are owned or controlled by BPI.

Part of our work involves monitoring the internet and taking action
against persons that use, facilitate, enable and/or authorise the use of
sound recordings in a manner that infringes the rights of the members of
BPI, PPL and AIM.
 
We rely on the data provided in whois registries to identify the contact
details of infringers using our members' sound recordings without
permission.  Such work relies on full and accurate data being available
through the whois registry.  The commercial services that anonymise the
registrant such as 123 Reg and Nameguard are further hindrance to our
work.

The service to our members would be negatively impacted if comprehensive
whois data was limited as proposed in Formulation 1.  Accordingly, we
would urge ICANN not to adopt Formulation 1.

Kind regards

BPI Legal Team
 
Riverside Building
County Hall
Westminster Bridge Road
London SE1 7JA
 
0207 803 1342