CAUCE Canada comments on WHOIS

["Neil Schwartzman" <neil@xxxxxxxx>]

Please accept the following comments sent on behalf of the board of
directors of CAUCE Canada

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CAUCE (US) and CAUCE Canada position on WHOIS data

CAUCE, the Coalition Against Unsolicited Commercial E-mail and CAUCE
Canada are the leading North American grassroots anti-spam
organizations.  They are both members of many cross-industry groups
including the London Action Plan at www.londonactionplan.org and the
Anti-Spyware Coalition at www.antispywarecoalition.org.  Both CAUCE
and CAUCE Canada are accredited ICANN At Large Structures.

Spam and related misbehavior such as phishing and spyware take a heavy
toll on Internet users.  Networks large and small devote an ever
increasing part of their resources to anti-spam measures merely to
keep their e-mail usable.  Phishing and other online fraud cause
direct damage to the users who are tricked into responding, and cause
all Internet users to be less confident in the Internet and less
willing to use it.

WHOIS has always been a key tool for both networks and law enforcement
to track and shut down spammers and phishers.  Both private and
government investigators use it every day to track spammers.  Even
forged data, which is regrettably common in WHOIS, still allows
skilled investigators to link domains to habitual spammers by way of
patterns found in the data.

The vast majority of Internet users will never register a domain of
their own, and are instead consumers of domains.  We are primarily
concerned with the interests of the non-registrant majority, but we
recognize that some registrants do have privacy concerns, and believe
that existing registrar anonymizing servers are adequate to protect
them and do not put an unreasonable burden on registrants.

A change to WHOIS that allows criminals a further opportunity to
obfuscate their activities by cloaking all WHOIS data will lead to
increased levels of privacy violations of by way of spam, viruses and
spyware.  Removing WHOIS data might provide marginally more privacy to
the relatively small number of individuals who register domains, at a
disproportionate cost to Internet users at large.  We oppose such a
change.


Neil Schwartzman
Chair, CAUCE Canada