As noted in previous statements, ISPCP members rely on Whois data in a variety of ways: 1. to research and verify domain registrants that could vicariously cause liability for ISPs because of illegal, deceptive or infringing content. 2. to prevent or detect sources of security attacks of their networks and servers 3. to identify sources of consumer fraud, spam and denial of service attacks and incidents 4. to effectuate UDRP proceedings 5. to support technical operations of ISPs or network administrators The ISPCP believes that requiring a consistent technical model across all TLDs advances our ability to use Whois in all these ways and strongly supports the recommendation by the Thick Whois Working Group to require the use of Thick Whois across all gTLD registries. Respectfully submitted, Mike O'Connor -- ISPCP rapporteur