> Attached is a redline containing two updates -

Thanks, and my apologies for being absent for most of the DT4 work ...


1.      When making purchase queries about a domain name, registration data
is used to determine the current Registrant and how to contact them.

^ This really only applies to _unsolicited purchase queries_ (as those
soliciting them list the domain as for sale directly or through one of the
many 2ndary market platforms) and so contact is handled/determined by that
platform and not through any data in WHOIS

It's also the source/cause of a significant number of fraud/scam attempts
including 2 extremely common issues:
* the escrow / valuation scam
* the reverse name hijacking scam

And I think it's important we hilight the problems/risks

3.      During acquisition, purchasers not only need to find out who they
should contact, but also the domain name's registration history to confirm
prior associations and to ensure that there are no issues with buying a
domain name "fit for purpose."

^ I'm not sure I understand this completely as there is no such thing as a
"domain name's registration history" as such, although it can be implied or
correlated from other data in was as described [ I understand the concept,
just not the exact wording ] I think "history of the domain name" would be
better

o       Additionally, WHOIS history is significant for understanding a
domain name's reputation via prior registrant WHOIS data. For example,
brokers may update WHOIS data before offering domain names for sale; in such
cases, assessing the domain name's reputation requires looking beyond
current WHOIS data to identify past registrants.

^ The idea of reputation when buying a domain has far more to do with
IP/hosting history than WHOIS data, use of the domain in spamming, hosting
certain types of content, use with phishing scams etc - who owned it
previously is mostly irrelevant compared to what it was used for

It's more like ...

Some domain purchasers will treat the history of a domain as potentially
significant, this can include:
* Historical WHOIS data such as who are the previous registrants
* History of hosting/ip-address changes and any content hosted
* Inclusion of the domain in lists of spamming/phishing/scamming domains
etc


4.      Registration data is also used during due diligence research to
identify the current Registrant of the domain name, confirm whether they
have a relationship with the Registrant Organization, and to determine other
domain names with which buyers or sellers are associated.

^ It wouldnt identify domains which "buyers" are associated with, so "which
buyers or sellers are associated." should be "which sellers may be
associated."


5.      In summary, registration data: informs buyers and sellers and those
they are working with; facilitates verification that parties can sell/buy
the domain name; makes it possible to carry out the purchase/sale
transaction; and enables verification (with a third-party) that the domain
name has actually changed hands before final payment is made from escrow.

^ registration data doesn't "makes it possible to carry out the
purchase/sale transaction;" (in any way) so can be deleted

^ 3rd-party escrows haven't historically relied on contact data updates as
it's quite possible for it to be wrong/outdated/hidden
(I've sold domains and 3 years later am still getting the WDRP notices each
year showing they've not yet updated the contacts)
although that may depend on the escrow service as a number of them are
registrars so determining change of control is simpler

I'd suggest changing "and enables verification" to "can assist with"


Domain Names for Specified Registrant   EWG recommendation to facilitate
transfer of all domain names owned by a single registrant or company in the
case of a merger/transition.

^ This doesnt currently exist, so I dont think we should be including it in
that section

Rob



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