Comment on limited use of proxy registrations

[John Meola <jmeola@xxxxxxxxxxx>]

To Whom It May Concern:
This is in regards to your proposal to limit the use of proxy registrations 
intended to obscure WHOIS information.  I write to you both in the capacity of 
someone who produces artistic content that may be subject to infringement and 
also as an information technology professional who has had to deal with abuse 
of service matters for a company that sends electronic greeting cards.  Through 
my experience in both of these roles, I am opposed to the use of anonymous 
domain name registrations.
While I understand there is a privacy concern with publishing WHOIS 
information, I have yet to encounter a case where the use of an anonymous 
domain name registration was done for legitimate reasons.  While I can see a 
purpose for them, such as in cases where a domain is used to advocate for 
political candidates or controversial issues, my encounters with them have been 
during investigations of terms of service violations and copyright infringement 
matters.
My former employer's primary business was designing and sending electronic 
greeting cards.  Inevitably, someone would exploit our services or violate our 
terms of service by sending bulk commercial email (spam).  We would then need 
to investigate the source of abuse and in many cases we would encounter a 
situation where the source domain's contact information was anonymized in 
WHOIS.  This prevented our legal department from issuing an immediate cease and 
desist letter to the spammer.
Likewise, in copyright cases, I have been unable to locate the source of a 
domain hosting copyrighted material without formal legal action due to 
anonymized WHOIS data.  This prevented me from issuing a DMCA notice in a 
timely fashion.
In both cases the use of anonymous registrations was not done to protect 
someone's identity from political opponents or oppressive foreign regimes.  It 
was done to obfuscate the identity of a persons engaged in offensive and 
illegal conduct.  Thus, I support ICANN's efforts to make WHOIS a transparent 
and reliable means of identifying domain owners.
Respectfully,
---
John Meola
315 7th St., Apt. 603Union City, NJ 07087Tel: (201) 339-1836