BITS & Roundtable Endorsement of Special Circumstances Model
To: Internet Corporation for Assigned Names and Numbers Re: Endorsement of Special Circumstances Model for WHOIS Data Base Dear Sirs and Madams: The Financial Services Roundtable and BITS appreciate the opportunity to comment on the proposal before the Internet Corporation for Assigned Names and Numbers (ICANN) to limit the type of information collected and maintained in the WHOIS data base. This a follow-up comment letter to the one that BITS submitted on April 14, 2006 (see http://www.bitsinfo.org/downloads/Comment%20letters/WHOISCommentBITSFINA LApr06.pdf). On September 21, 2006, our member companies endorsed the "Special Circumstances Model" with the understanding that the "Special Circumstances Model" provides unrestricted access to WHOIS information, while, at the same time, provides a mechanism to protect the privacy concerns of individual, non-commercial registrants who can demonstrate a need to mask their WHOIS data. Our members, as well as numerous other financial institutions use the WHOIS data to identify cyber squatters and domain infringement, investigate online frauds and phishing, manage their domain names and intellectual property, and conduct e-commerce by researching other online entities. Full WHOIS registration data is essential to perform these functions. Our members do not support the Operational Point of Contact (OPOC) proposal because it would suppress public access to the full registration data of every registrant including corporations, businesses and others who, by having a website, are advertising their existence to the public. This suppression goes far beyond what legitimate privacy concerns require. In addition, the OPOC proposal does not provide for any time limits associated with data requests from a third party to the OPOC nor are there any defined sanctions for failing to comply with a request. Attached is a list of our member companies which includes 100 of the largest US-based financial institutions. The Financial Services Roundtable is a national association that represents 100 of the largest integrated financial services companies providing banking, insurance, investment products, and other financial services to American consumers. Roundtable member companies provide fuel for America's economic engine, accounting directly for $50.5 trillion in managed assets, $1.1 trillion in revenue, and 2.4 million jobs. BITS is a nonprofit industry consortium that shares its membership with The Financial Services Roundtable. BITS' mission is to serve the financial services industry's needs at the interface between commerce, technology and financial services. BITS works as a strategic brain trust to provide intellectual capital and address emerging issues where financial services, technology and commerce intersect. BITS focuses on key issues where industry cooperation serves the public good, such as critical infrastructure protection, fraud prevention, and the safety of financial services. BITS' activities are driven by the CEOs and their direct reports-CIOs, CTOs, Vice Chairmen and Executive Vice President-level executives of the businesses. For more information, go to www.bitsinfo.org <http://www.bitsinfo.org/> . If you have any further questions or comments on this matter, please do not hesitate to contact me or John Carlson at john@xxxxxxxxxxx <mailto:john@xxxxxxxxxxx> or 202- 289-2442. Sincerely, Catherine A. Allen CEO, BITS Richard M. Whiting Executive Director and General Counsel The Financial Services Roundtable John Carlson Executive Director, BITS 1001 Pennsylvania Avenue, NW Suite 500 South Washington, D.C. 20004 (202) 589-2442 (office) (301) 908.1141 (cell) e-mail: john@xxxxxxxxxxx <mailto:john@xxxxxxxxxxx> www.bitsinfo.org <http://www.bitsinfo.org/> "This e-mail is intended solely for the addressee(s) and may be legally privileged and/or confidential. If you are not the intended recipient, be aware that any disclosure, copying, distribution, forwarding or use of the contents of this email, including any information in attachments, is prohibited. Additionally, if you are not an intended addressee, please delete this email and attachments and all copies from your system, destroy any hard copies and immediately notify the sender by telephone (202.289.4322) or by email. Any unauthorized retention, use or disclosure of this email and/or attachments may be unlawful. Thank you."