SIIA Comments on the Preliminary Report of the Whois Task Force

["Mark Bohannon" <mbohannon@xxxxxxxx>]

MEMORANDUM TO:  Whois Task Force 

FROM:                   Mark Bohannon
                        General Counsel & SVP Public Policy
                        Software & Information Industry Association
(SIIA)


The Software and Information Industry Association (SIIA) appreciates
this opportunity to comment on the preliminary report of the Whois Task
Force regarding the purpose of Whois.  

As the principal trade association of the software and digital content
industry, SIIA represents over 700 companies around the world that
develop and market software and electronic content for business,
education, consumers and the Internet.  Membership includes some of the
largest and oldest technology enterprises in the world, as well as many
smaller and newer companies.  All these diverse companies have in common
the need for a secure and stable online environment, in which consumers,
businesses and other institutions will have confidence.  

SIIA and its member companies strongly oppose proposed Formulation 1 for
the "purpose of Whois."  This proposal would restrict the uses of Whois
data - and ultimately the range of data collected and made available ---
to the minimum necessary to "resolve issues related to the configuration
of the records associated with the domain name within a DNS nameserver."
This proposal does not accord with the reality of how Internet users -
including SIIA member companies - use Whois data today, nor with how
they have used it in the past.    

Domain name registration data contained in Whois is used for a wide
range of legitimate and beneficial purposes.  It helps consumers and
businesses learn more about who they are dealing with online.  It is
also an important tool in combating phishing and other forms of online
fraud that reduce public confidence in the Internet as a place to work,
play, learn and do business.  Whois is also an important factor in
investigations of infringement of intellectual property rights online.
Companies routinely use Whois to help manage their own domain name
portfolios.  In sum, access to a full set of Whois data is critical to
maintaining transparency and accountability online.  

Few, if any, of these valuable uses fall within the narrow confines of
resolving  "issues related to the configuration of the records
associated with the domain name within a DNS nameserver."  We urge ICANN
not to make a radical break with long-standing Whois policy by
restricting this data to this narrow set of uses.  

Formulation 1 should be rejected.  


Thank you for considering our views.  


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This is a message from:

Mark Bohannon
General Counsel & SVP Public Policy
Software & Information Industry Association (SIIA)
1090 Vermont Avenue, NW  6th Floor
Washington, DC   20005
Direct Line:    202-789-4471
Main Switchboard:       202-289-7442
Fax:            202-289-7097
Email:          Mbohannon@xxxxxxxx
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