First, I would like to thank Kieren for his efforts that have resulted in ICANN's Compliance Director having a look at the current WDPRS system problems. Ms. Burnette has stated: "We were not aware that follow-up notices were not being transmitted to reporters. I have asked the site administrator to address this problem right away." http://public.icann.org/node/657#comment-22 Next, I'd like to discuss the topic of user empowerment. The Whois Data Problem Reporting System is a tool used by consumers to flag inaccurate WHOIS data. On a daily basis, users are beseiged by junk mail associated with domains that have been registered with false data. In response, individuals and networks have acted to utilize the WDPRS to bring down these offending domains. The problem, of course, is that a very high percentage of registrations have inaccurate data (owing to [1] ICANN's failure to deal with privacy concerns; [2] owing to ICANN's lousy policy for dealing with inaccurate data that places way too much discretion in the hands of the registrars; and [3] owing to the worldwide failure to effectively deal with SPAM and the criminal element). This means that we need to have either a very robust, scalable WDPRS that can handle this high percentage or a set of policies designed to properly vet registrations prior to activation. As most in the registrar community have thus far chosen not to scrutinize any registration fields other than the data associated with billing contacts, we need to act to force them to change their modus operandi. As I sincerely doubt that we will see any positive changes in the upcoming RAA revisions on this topic, I am of the view that we need to bolster the WDPRS system so that registrars are forced to manually respond to thousands of requests daily -- I am sure that in response to such a deluge they might reconsider their current stance on data verification efforts -- manual efforts will in the long run cost them alot more than the cost of implementing automated data verification processes. Currently, the system can handle only a few thousand complaints daily, but we have firms waiting in the wings that could put through 10,000 valid complaints a day. We need to talk about improving the WDPRS capabilities so that those that want to clean up the mess that ICANN has helped to create through its lax policies can better get on with their efforts to protect and serve the public. Improving sytem capabilities is one consideration; another consideration to look at is the registrar use of WHOIS rate limiters that make it difficult for the WDPRS to process large volumes of complaints. Beyond that we need to look at ICANN's manpower situation and determine how much more personnel will be required to properly manage the WDPRS process (in terms of regular oversight activities, periodic audits and system management needs). Current processing and staffing levels are just not designed to meet the size and scope of todays problems. All of the above call for either budgetary decisions to be reached, or new policy to be drafted. While we can certainly attack on both fronts, what we cannot do is fail to properly empower the users by allowing this Reporting System to continue on its faltering path without improvements being made. I would like to see ALAC comments on the budget address this important user issue. ____________________________________________________________________________________ Never miss a thing. Make Yahoo your home page. http://www.yahoo.com/r/hs