Comment on WHOIS Task Force Report

["Peter Glantz" <pglantz@xxxxxxxxxxxxxxxxx>]

Dear Sir or Madam:

        We appreciate the opportunity to provide public comments on
behalf of Domain Capital, LLC ("Domain Capital").  Domain Capital,
founded in 2005, is an intangible asset-based financing company that
recognizes and accepts Internet domain names as assets.  Domain Capital
provides financing to the resale market of Internet domain names.  As
such, WHOIS registration and associated rights accompanied by such
registration are of utmost importance to the success of Domain Capital's
business.

        Domain Capital is the registered owner of all Internet domain
names that are collateralized by Domain Capital's borrowers.  However,
Domain Capital's borrowers retain the right to configure the records
associated with the applicable domain name within a DNS name server.
For this reason, Domain Capital supports the primary purpose of listing
the "Operational Point of Contact" ("OPOC") within a WHOIS service, on
condition that the OPOC's rights are limited to configuring the records
associated with the applicable domain name within a DNS name server.
After all, the whole purpose of providing an OPOC via a WHOIS service is
to address technical issues that need to be resolved.  The OPOC is not
intended to deal with domain name issues such as the ownership of domain
names, trademarks, buying domains names, etc.

        Finally,        Domain Capital does not object to the publishing
the OPOC's name, address, telephone number and email address via the
WHOIS service.    

        We thank you in advance for taking this comment into
consideration prior to the submission of the final task force report to
the GNSO Council.
 
Very truly yours,

Peter J. Glantz, Esq.
General Counsel
Domain Capital
2050 Center Avenue
Suite 600
Fort Lee, New Jersey 07024
Phone: (201) 302-5100 ext. 21
Fax: (201) 302-0708
Email: pglantz@xxxxxxxxxxxxxxxxx
http://www.domaincapital.com


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