FW: Comments of American Heart Association on Whois Taskforce Preliminary Report

["Metalitz, Steven" <met@xxxxxxx>]

The following comment is being resubmitted as it does not yet appear to
have been posted on the comment archive. 
 
Steven J. Metalitz | Mitchell Silberberg & Knupp LLP | 2300 M Street,
N.W., Suite 800, Washington, D.C. 20037 | tel: 202 973-8132| fax: 310
231-8432| met@xxxxxxx

 

________________________________

From: Lea Fisher [mailto:lea.fisher@xxxxxxxxx] 
Sent: Friday, January 12, 2007 5:12 PM
To: whois-services-comments@xxxxxxxxx
Subject: Comments of American Heart Association on Whois Taskforce
Preliminary Report



To Whom It May Concern:

On behalf of the American Heart Association (AHA), including the
American Stroke Association (ASA) and over 22.5 million AHA and ASA
volunteers and supporters, we appreciate the opportunity to submit our
comments in response to the GNSO Whois preliminary task force report on
Whois services.  

AHA has serious concerns about the Operational Point of Contact (OPoC)
Proposal included as one option in the preliminary report.  The OPoC
proposal would severely limit the amount of domain name registrant
information publicly available.  Under the OPoC proposal, only the
registrant's name and country would be accessible via the Whois service.
This significant change from current policy would severely hinder AHA's
ability to identify and shut down fraudulent websites falsely portraying
themselves to be operated by or affiliated with the AHA.  

Also included in the preliminary report is a Special Circumstances
Proposal that would preserve the status quo on Whois data, except for
individual and non-commercial registrants who are able to demonstrate
the need for protecting data for personal safety reasons.  While we have
concerns about how a new centralized mechanism for recognizing
registrants would operate, of the two proposals offered in ICANN's
report, we find the Special Circumstances Proposal to be preferable
because of its protection of publicly available data. 

The American Heart Association is a national voluntary health agency
whose mission is to reduce disability and death from cardiovascular
diseases and stroke.  We own and maintain approximately 40 web sites,
and rely upon Whois data to preserve the integrity of these sites.  The
American Heart Association urges ICANN not to adopt the OPoC proposal.
Instead, we urge ICANN to provide a clear procedure for accessing Whois
data, to take additional steps to ensure that data supplied by domain
name registrants is accurate and current, and to phase out the proxies
that currently conceal the identity of registrants.

Respectfully submitted,

Sue Nelson

Vice President of Federal Advocacy

American Heart Association