Comment Regarding Whois System

["Debra Hughes - Legal" <Debra.Hughes@xxxxxxxxxxxxxxxx>]

To the members of the GNSO Council and ICANN:

Wal-Mart Stores, Inc ("Wal-Mart") strongly urges the GNSO to support
Motion 2 and reject Motions 1 and 3, which are slated for vote by the
GNSO on October 31, 2007.  

Wal-Mart regularly uses the Whois system to research and contact the
registrants of infringing and fraudulent domain names to protect our
customers from online scams and other illegal activity.  Wal-Mart urges
the GNSO to support Motion 2, advanced and supported by INTA's Internet
Committee, which proposes a thorough study of the legitimate uses and
the abuses of Whois data, before making a policy change that would alter
the current structure of the Whois system relied upon by consumers,
brand owners and law enforcement personnel to research and combat online
fraud.  

In addition, Wal-Mart urges the GNSO to reject Motions 1 and 3.  Motion
1 proposes a new "Operational Point of Contact" ("OPoC") but the legal
responsibilities of the OPoC are undefined and the proposal limits the
amount of publicly displayed domain name ownership information - the
type of data regularly relied upon by consumers, law enforcement
officials and brand owners to protect consumers and intellectual
property rights on the Internet.  Motion 3 proposes eliminating all
contractual obligations that require registrars to display domain name
ownership and contact details and effectively abolishes the entire Whois
system for Generic-Top-Level domain names.  Further, removing access to
the Whois database could eliminate disincentives for abuse perpetrated
over the Internet.

We thank ICANN for the opportunity to provide this comment.

Sincerely,

Debra Y. Hughes, Esq.
Assistant General Counsel
Wal-Mart Stores, Inc.


Debra Y. Hughes, Assistant General Counsel
Phone: 479.277.1695  Fax: 479.277.5991

Wal-Mart Stores, Inc.,
702 S.W. 8th Street (MS 0520)
Bentonville, AR 72716-0520
debra.hughes@xxxxxxxxxxxxxxxx

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