Preliminary Task Force Report on Whois Services

["TLDC" <tldc@xxxxxxxxx>]

1. General Comment
2. Comment regarding Operational Point of Contact
3. The five proposals in the discussion on access to data

1. General Comment

I am not surprised that the task force did not reach agreement on the
purpose of the "who is contacts" as they can be used for a variety of
purposes. From marketing, to legal, to trouble shouting.

2. Comment regarding Operational Point of Contact

The way I see it is, that the registered name holder is fully
responsible for the domain content.

If there are any issues with the domain content than we must know whom
the domain belongs to and where we can take legal action against the
registered name holder.
So the postal address of the registered name holder would be essential.

If we would discontinue with publishing the full address than the oPOC
may receive plenty of requests to hand over the address of the
registered name holder. 

And who would be the oPOC ? The registrar, web space hoster, or DNS
Server operator.

In general I don't mind how we label the technical staff weather its
technical staff or oPOC.

I would like to have three contact records at who is.
The name and address of the registered name holder.
The name, address, email, website, phone of the registrar.
The name, address, email, website, phone of the web space hoster (if
applicable)

The phone and email address of the registered name holder could be
optional in who is.

There are situations where the registered name holder puts some
inappropriate content onto his web site and abandons his site. Then it
is good to have technical contacts for suspending his domain.

I also see the need that in some cases it must be possible not to
publish the contact details of the registered name holder. But in these
circumstances we should get an alternative legal contact.

And I support the idea of removing the billing contact from who is.
Only the registrar needs to know where the money is coming from, not the
general public.

3. The five proposals in the discussion on access to data

(1) Representatives of the registrar constituency proposed that such
data could
be made available by contacting the registrar of record for the domain
name,
without any new rules or policies, but be made subject to best
practices. Today,
registrars handle many requests for other information not published in
the Whois,
and they expect to handle requests to data removed from the Whois in a
similar
manner.

I think that we would need new rules or policies for this.
Like how to contact the registrar, by web interface, email, phone, fax,
in person or by mail.
And how much time would they have to work on a request.
Do they need to provide the service for free or for a fee?

With kind regards


Matthias Jungbauer