Hello Jim, I thought about that but then realized our statement would immediately NOT scale to the current operations of .NAME, .TEL and .CAT since those registries do not "provide direct access to" the Thick WHois data. Suppose Verizon was to apply for a .VERIZON gTLD and allocate second level domains to its FIOS customers. Now in this scenario Verizon has pristine contact data, it physically knows where the fiber terminates in a customer's home and sends that customer a bill which is paid every month. Now do I expect that Verizon would publicly make available the whois data of every Verizon subscriber? Considering how registrars use to mine whois data to pouch other registrars customers, I do not think Verizon wants to allow Comcast to cherry pick its FIOS customer list. What law enforcement and third parties that have been harmed by a domain name registrant want is quick and prompt access to accurate whois data when something bad happens. That is why I used the word "direct access to". Providing third parties with direct access to thick Whois data which contains nothing more than proxy data is useless to those people trying to correct/prevent the harm. The BC needs to be mindful that there are many moving parts in the Whois discussion, and that there is no guarantee that proxy/privacy services will continue to be a means to shield personal data. Many of the corporate/brand BC members that have applied for gTLDs need to be mindful of these very important operational and legal issues. The traditional one size fits all approach of policy formulation in the .COM gTLD world will no longer scale in the near foreseeable future. Best regards, Michael From: Baskin, James F (Jim) [mailto:james.f.baskin@verizon.com] Sent: Monday, May 14, 2012 2:18 PM To: Michael D. Palage; ''Bc GNSO list '' Subject: RE: [bc-gnso] Clarification How about "provide direct access to" ? From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Michael D. Palage Sent: Monday, May 14, 2012 2:01 PM To: ''Bc GNSO list '' Subject: [bc-gnso] Clarification Hello All, I am a little confused by the wording "[w]e believe that requiring all Registries to comply with Thick Whois." How does one "comply" with thick whois? Registries such as .NAME, .TEL and now .CAT "operate" their registry by collecting Thick whois data, but comply with national privacy laws in how they provide access to that data set. Having worked with a large number of new gTLD applicants with a variety of business models, I think the BC needs to be a little more careful in how we word our statements so they scale in a future world of thousands of new gTLDs. Therefore, I would recommend that we change the phrase "comply with" to "have direct access to." Best regards, Michael