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Oppose proposal on domain name privacy
- To: <comments-ppsai-initial-05may15@xxxxxxxxx>
- Subject: Oppose proposal on domain name privacy
- From: Mark Maszak <mark_maszak@xxxxxxxxxxx>
- Date: Wed, 24 Jun 2015 19:41:40 -0700
Hello,
I learned today that you're considering a change to block access to domain
proxy registration services in certain circumstances.
This idea is so unbelievable that I thought it must be a joke. There's
already far too much of our personal information easily available online
today. Forcing people to provide their contact information in certain (not
clearly defined) circumstances will end up having a chilling effect on free
speech.
Regarding some of the specific questions you're seeking answers to:
"Should registrants of domain names associated with commercial activities
and which are used for online financial transactions be prohibited from
using, or continuing to use, P/P services? If so, why, and if not, why not?"
- No, they should not be prohibited from using P/P services. If
the transactions are illegal, there are existing methods for the people who
have a stake in the transaction to follow up with P/P providers to discover
the actual site owner.
"If you agree with this position, do you think it would be useful to adopt a
definition of "commercial" or "transactional" to define those domains for
which P/P service registrations should be disallowed? If so, what should the
definition(s) be?"
- While I disagree with the position, if you do adopt it, it is
CRITICAL that you clearly identify "commercial" or "transactional". A
failure to do so would leave it up to the implementers, which means you'll
get a variety of behavior. I think it would be difficult to clearly
identify all possible types of transactional activity. I'd suggest
targeting the definition at what sort of transactions are acceptable & still
allow you to use P/P services. Then users will know that anything beyond
that is clearly out of bounds. There should be a process defined by which
someone can request additional clarification to this list (hopefully not
something that's bogged down by years of committee review). If any future
changes result in additional clarifications, all existing domains using P/P
services must be "grandfathered in". In other words, a change in the rules
shouldn't result in the disclosure of any private information.
- And on a related note, you will also need to define a clear
process by which people can report sites that appear to be in violation of
said rules. I personally feel this will be an unwieldy process, and put a
burden on the P/P providers. But you need to rely on someone to enforce
this rule, and I don't know who else it would be. If you do not feel it can
be properly enforced, then it should not be enacted.
So to sum up: I am strongly opposed to any idea to restrict the use of P/P
services.
Thanks.
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