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Allow continued domain privacy

  • To: comments-ppsai-initial-05may15@xxxxxxxxx
  • Subject: Allow continued domain privacy
  • From: Chris Gebhardt <chris@xxxxxxxxxxx>
  • Date: Wed, 01 Jul 2015 09:04:07 -0500

Dear members of the Working Group,
I'm pleased to offer comments for your consideration regarding whois privacy. We have provided website design and hosting, as well as other services, since 1996. Our client list includes Fortune 100 companies, "mom and pop" operations and everything in-between.

We utilize privacy services for a number of our clients who prefer their domain registration not reflect personal contact information.

One of the great things brought about by the mass adoption of the Internet as a platform for communication and commerce is the way that the playing field has been leveled for big operators and small independents alike.

The objection to whois privacy appears to center around an inability to contact the registrant in the event it is necessary to communicate with the registrant for a given reason. This is simply not the case, since accredited domain privacy providers will always forward pertinent messages to the registrant by means of systems already in place.

The Whois Accuracy Program Specification of ICANN's 2013 Registrar Accreditation Agreement (RAA) already calls for the verified accuracy of domain registration information. Domain registration providers are already ensuring that valid contact information exists for domains in their registry. It is therefore held that when a domain registration provider has verified contact information, and is then called to provide privacy and forwarding services for a domain, a reasonable method to make contact with a domain holder already exists.

Whois privacy can play an important role here by providing the same protection afforded to large corporations who can afford to mask their domain ownership under holding companies, lawyers, post office boxes and other means of obfuscation. While there will always be bad actors, it does not make sense to throw out an entire system of privacy protection that is used for legitimate purposes by responsible domain holders. To do so would unjustly penalize small operators and runs counter to the long-held principals of Internet culture.

Eliminating domain privacy as it currently exists will only serve to endanger free speech, discourage competition and inhibit innovation. Free speech, healthy competition and innovation. Those principals have always been the foundation of Internet commerce.

Throughout the course of my 20-year career as a professional Internet service provider, I have always taken great personal pride to play a part in changing and enhancing the ways people work, play and interact with each other.

The continued availability of domain privacy and its ability to protect entrepreneurs, small business operators, non-profits and others should be considered crucial. I urge the Working Group to thoughtfully consider the negative impact of implementing changes to domain privacy rules and recommend against adoption of rules that would be onerous to domain registration providers and registrants alike.

Chris Gebhardt, President
VIRTBIZ Internet Services
chris@xxxxxxxxxxx | (972) 485-4125

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