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WHOIS Privacy Must Always Be An Option

  • To: "comments-ppsai-initial-05may15@xxxxxxxxx" <comments-ppsai-initial-05may15@xxxxxxxxx>
  • Subject: WHOIS Privacy Must Always Be An Option
  • From: M B <match_art@xxxxxxxxxxx>
  • Date: Sat, 4 Jul 2015 03:47:11 -0500


This email is in response to the recently proposed rule change regarding 
privacy and proxy service providers.

TL;DR: There should be no change made to the current system, which gives 
registrants the option to protect their private information through P/P 

Exposing a small business owner's private information in the WHOIS records does 
not protect the consumer who – in most cases – does not even know that the 
service exists. Nor is it the first source they check to ensure that a business 
is legitimate.

Instead the proposed change would aid criminals and fraudsters who already have 
too easy of a time stealing identities and engaging in harassment, abuse, and 
character assassination.

* Everyone has the right for their private information to be kept private
* Unless accompanied by a court order, private information should not be given 
out, period

Question: 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?

Answer: No. Exposing private information for the legitimate small business 
owners and individuals who administer a website with "commercial activities"* 
is foolish. This will not provide the average consumer with another metric to 
confirm a website's identity.

Removing the ability to make use of P/P services is not going to stop 
registrants with criminal intent. The notion that they are using their real 
information now and will be foiled once they are no longer able to use P/P 
services is naive. They are not using their real information now and they will 
not be using it in the future.

* You are proposing this change for websites with "commercial" or 
"transactional" activities. However, the picture is not black and white.

Do the same requirements apply to blogs that make use of adsense and 
sub-domains on platforms like Blogspot? How about the amateur craftsman/woman 
who sells their creations on Etsy/Ebay/Amazon? Unlikely, and with the WHOIS 
service impossible. Maybe the site owner who relies on 3rd party services like 
PayPal to manage payments? The author who promotes their book on their website, 
yet is sold elsewhere?

The only ones that will profit from the proposed change will be the medium and 
large businesses who have addresses not directly associated with a private 
individual. The private person, the small business owners will think twice 
before they expose themselves to harassment and risk associated with 
immortalizing their full name, telephone number, and home address online.

And with that the creativity and entrepreneurial drive that was once the 
backbone of the Internet will be broken.

Thank you.                                        

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