[Fwd: A commet (third attempt to submit)]
First, it fails to clearly articulate who is the intended beneficiary of these policies. Nor does it articulate anything more than a few tired and unrevealing phrases about the purpose of collecting "whois" data, much less how that collection improves the technical stability of DNS as measured in terms of efficiently and quickly transforming DNS query packets into DNS response packets without prejudice against any query source or query content.
In addition, the report fails to even consider measures that have been discussed in the past - ICANN's memory is very short.
For example, it has been raised in the past that anyone who asks to view whois data should be required to submit to a permanent and publicly visible ledger the following information:
- Identity (i.e. name, contact information) of the person requesting access.
- A short but factual statement describing, with particularity, what specific rights of the person making the inquiry are believed to have been violated by the data subject described in the whois record being accessed.
As for the material that is in the report:
The operational point of contact is a useful idea.
The special circumstances proposal is wrong-minded in that it turns the privacy equation around. Privacy should be the default state of affairs, not the exception.
We have seen so many examples of how the intellectual property industry has become an abusive industry. The assault on individual rights by the RIAA and its thousands of lawsuits based on a dragnet sweep of IP address information - indicates what kinds of use we can expect the intellectual property industry to make of whois data.
The special circumstances proposal is being made by an industry that has demonstrated that it wants that data as a weapon for its own purposes.
ICANN, being a body whose interest is the technical stability of the internet, ought not to be granting such political and economic favors to one particular industrial segment.