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Re: FW: Comments of American Heart Association on Whois Taskforce Preliminary Report

  • To: "Metalitz, Steven" <met@xxxxxxx>
  • Subject: Re: FW: Comments of American Heart Association on Whois Taskforce Preliminary Report
  • From: "GNSO.SECRETARIAT@xxxxxxxxxxxxxx" <gnso.secretariat@xxxxxxxxxxxxxx>
  • Date: Mon, 15 Jan 2007 23:35:02 +0100

Thank you very much Steve, these comments have reached the public comment list:

Kind regards,


Metalitz, Steven a écrit :
The following comment is being resubmitted as it does not yet appear to have been posted on the comment archive.

Steven J. Metalitz | Mitchell Silberberg & Knupp LLP | 2300 M Street, N.W., Suite 800, Washington, D.C. 20037 | tel: 202 973-8132| fax: 310 231-8432| met@xxxxxxx

*From:* Lea Fisher [mailto:lea.fisher@xxxxxxxxx]
*Sent:* Friday, January 12, 2007 5:12 PM
*To:* whois-services-comments@xxxxxxxxx
*Subject:* Comments of American Heart Association on Whois Taskforce Preliminary Report

To Whom It May Concern:

On behalf of the American Heart Association (AHA), including the American Stroke Association (ASA) and over 22.5 million AHA and ASA volunteers and supporters, we appreciate the opportunity to submit our comments in response to the GNSO Whois preliminary task force report on Whois services.

AHA has serious concerns about the Operational Point of Contact (OPoC) Proposal included as one option in the preliminary report. The OPoC proposal would severely limit the amount of domain name registrant information publicly available. Under the OPoC proposal, only the registrant’s name and country would be accessible via the Whois service. This significant change from current policy would severely hinder AHA’s ability to identify and shut down fraudulent websites falsely portraying themselves to be operated by or affiliated with the AHA.

Also included in the preliminary report is a Special Circumstances Proposal that would preserve the status quo on Whois data, except for individual and non-commercial registrants who are able to demonstrate the need for protecting data for personal safety reasons. While we have concerns about how a new centralized mechanism for recognizing registrants would operate, of the two proposals offered in ICANN’s report, we find the Special Circumstances Proposal to be preferable because of its protection of publicly available data.

The American Heart Association is a national voluntary health agency whose mission is to reduce disability and death from cardiovascular diseases and stroke. We own and maintain approximately 40 web sites, and rely upon Whois data to preserve the integrity of these sites. The American Heart Association urges ICANN not to adopt the OPoC proposal. Instead, we urge ICANN to provide a clear procedure for accessing Whois data, to take additional steps to ensure that data supplied by domain name registrants is accurate and current, and to phase out the proxies that currently conceal the identity of registrants.

Respectfully submitted,

Sue Nelson

Vice President of Federal Advocacy

American Heart Association

Glen de Saint Géry
GNSO Secretariat - ICANN

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