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BITS & Roundtable Endorsement of Special Circumstances Model

  • To: <whois-comments@xxxxxxxxx>
  • Subject: BITS & Roundtable Endorsement of Special Circumstances Model
  • From: "John Carlson" <John@xxxxxxxxxxx>
  • Date: Fri, 12 Jan 2007 16:39:16 -0500

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


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


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.





Catherine A. Allen




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/> 
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Attachment: BITSFSRWHOISCommentLetterJan122007.pdf
Description: BITSFSRWHOISCommentLetterJan122007.pdf

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