Thanks, Susan, for your development of the BC comments, and Steve, for your addition. I wonder if the comments need a paragraph or at least a sentence or two that also notes the importance of WHOIS to business, and the long standing involvement of this constituency in WHOIS issues; our concern about issues like fraud, abusive registrations, misuse of domain names to engage in phishing, and other deceptive practices. WE should take care to distinquish the concerns of the BC as being focused about concerns that come from the perspective of business users. Business users are concerned about abusive use of registered domain names because abusive use or misuse adds in risks to users of the Internet; leads to fraud and other problems. Accurate and available WHOIS is a critical part of ensuring trust on the Internet. Such a paragraph could be an introduction, or a closing statement as an addition to the comments. I agree, broadly with Steve's additions but offer a couple of suggestions for your consideration: I might reword number 5 a bit. We want ICANN to continue regularly scheduled WHOIS accuracy analysis and publish it, as they have with this report. We further believe that such fact based analysis can help to identify the needed areas for improvements in registrar fulfillments of their responsibilities to gather, publish and maintain accurate and accessible WHOIS. I would perhaps change the statement "Registrars manage to gather... ", to read: "Processes to gather accurate information are undertaken by Registrars in the collection of credit card and other form of payment information. Valid WHOIS data should be a criteria to complete registration of a domain name." And, like Steve and others in the BC, I fully support the importance of referencing the importance of undertaking the WHOIS studies that continue to be discussed within the GNSO policy Council. You might add in a sentence to 6. "Undertaking these long awaited studies will significantly contribute to the fact based understanding of all ICANN stakeholders. The BC believes that such fact based research will help to inform the further consideration of WHOIS policy." Date: Tue, 13 Apr 2010 14:35:46 -0400 Subject: Re: [bc-gnso] Draft Comments on ICANN's Study of the Accuracy of the WHOIS Registrant Contact Information From: sdelbianco@netchoice.org To: skawaguchi@facebook.com; bc-gnso@icann.org Re: [bc-gnso] Draft Comments on ICANN's Study of the Accuracy of the WHOIS Registrant Contact Information Susan — if you’re accepting any additional edits at this point, I wanted to offer some text that could strengthen our hand in getting funding for additional Whois studies. Two weeks ago I prepared arguments favoring studies, and here are 2 edits that fit nicely with the Recommendations at the end of your comments: 5. Continue studying the accuracy of the WHOIS. ICANN should set higher standards for accurate Whois data for registrants. After all, registrars manage to gather credit card information that’s sufficiently accurate to ensure they are paid by registrants. Let’s find ways to ensure that registrars apply the same diligence in collecting and validating public Whois data. 6. Fund additional WHOIS studies requested by Council for which staff is prepared to proceed. The Misuse and Registrant ID studies are likely to generate data that would affect policy decisions and compliance work, especially with so many new TLD operators coming online next year. These studies will help satisfy the Affirmation of Commitments (9.3.1), which requires ICANN to review the extent to which WHOIS “meets the legitimate needs of law enforcement and promotes consumer trust”. Finally, we will want to have these study results on hand so they can be compared with study results after new TLDs are operating for one year, as required by the Affirmation of Commitments item 9.3 On 4/9/10 8:35 PM, "Susan Kawaguchi" <skawaguchi@facebook.com> wrote: Hello All, Attached please find draft comments on the WHOIS Accuracy Study. Comments are due on April 15th. Please send me your comments, revisions or concerns prior to the 15th. Thanks Steve for your help. Susan Kawaguchi Domain Name Manager Facebook Inc. 1601 S. California Avenue Palo Alto, CA Phone - 650 485-6064 Cell - 650 387 3904 NOTICE: This email (including any attachments) may contain information that is private, confidential, or protected by attorney-client or other privilege. Unless you are the intended recipient, you may not use, copy, or retransmit the email or its contents." -- Steve DelBianco Executive Director NetChoice http://www.NetChoice.org and http://blog.netchoice.org +1.202.420.7482