Cheryl and members of the ALAC: The user community has long been concerned with the WHOIS data accuracy issue. As you are aware, the GAC has previously issued a WHOIS Principles document that notes that "gTLD WHOIS services should provide sufficient and accurate data about domain name registrations..."; the GAC has also requested that a number of WHOIS studies be conducted. Concurrently the GNSO Council's WHOIS hypotheses Working Group has been working on supporting language designed to lead to an investigation of a number of related open issues. The ALAC is in a position to support these initiatives through its own investigation into WHOIS data accuracy issues. Allow me to remind everyone that the Board has set up Advisory Committees for the express purpose of conducting investigations that will result in the release of findings and recommendations. It would be appreciated if the ALAC would agree to conduct a formal investigation of the following topic: issues pertaining to the WHOIS Data Problem Report System (WDPRS). This concern is being raised in view of the following considerations: 1. It has been reported that the WDPRS has been down for the whole month of April 2007. It has also been down on these dates: 1/22/2008 2/2/2008 2/5/2008 2/12/2008 2/26/2008 3/6/2008 4/5/2008 6/17/2008 2. On 19 March a concerned WDPRS submitter reported to ICANN's Public Participation site: "I have not received a 45-day WDPRS follow-up since 20-Jan-2008, even though I have filed WDPRS reports almost daily for the past several months. Has ICANN discontinued WDPRS follow-ups? I have emailed the webmaster a few times about this matter, but as with all emails to the webmaster on any subject, I have never received a reply. Dale H. Cook, Chief Engineer, Centennial Broadcasting, Roanoke/Lynchburg, VA - WZZI / WZZU / WLNI / WLEQ; 3. Just before the Paris session, the WDPRS stopped accepting reports from the largest submitter of inaccurate WHOIS data; 4. The WDPRS has been newly reconfigured with rate limiters that serve to obstruct the reporting process. Prior submission rates allowed for three report submissions per minute (the daily ceiling of reports was 4320). It would now take 1 month to submit this quantity of reports with the programmed delays; 5. The largest WDPRS submitter receives reports in the range of 5000 – 10,000 illicit unique domains per day and has noted that it would hypothetically take 4 years to report a month’s worth of false registrations through the current WDPRS. 6. Rather than working in cooperation with the submitting agents and jointly fashioning a more scalable system, ICANN Staff has resolved to implement "a system that will ensure staff reviews every alleged inaccuracy report for a particularized inaccuracy before sending the report to the registrar". This approach assuredly will not scale and can be expected to inadequately serve the needs of the user community. 7. We are aware that the reporting of inaccurate WHOIS Data is also hampered by proxy services that withhold underlying data. While it may be appropriate for individuals to utilize such privacy services, it remains inappropriate for those engaged in commercial transactions over the internet to obfuscate/shield their contact data -- such actions do not serve the interests of users/consumers. The ALAC could be of value to the user community were it to request that the GNSO engage in policy development pertaining to such proxy services. We currently receive a lot of data from ICANN's compliance department, but lots of data does not equate with transparency. The WDPRS represents a problem area about which the Compliance Department has not been sufficiently forthcoming. In the May Compliance Department report it was noted that staff: "Created a new database to allow processing of WDPRS reports; Raised the report limiter to accommodate an increased number of reports; and Monitored (and continues to monitor) daily activity for system response and capacity. As part of a long-term solution, ICANN is conducting a system redesign that will improve operational effectiveness, data processing, accuracy, data recovery, and increase data capacity." By all indications an increased number of reports is not being accommodated and the system redesign has totally failed to meet its objectives. Those of you that read the SSAC reports will note their recent analysis of 4444 registrations that determined that: – 10% were missing admin contact name (439 records) – 11% were missing admin contact email (502 records) – 12% were missing admin contact address (514 records) With this level of inaccuracy one has to wonder if registrars are actually investigating inaccuracies as required by Section 3.7.8 of the RAA, or if that entire community is just going through the motions. A thoroughgoing investigation is warranted. It certainly would be appreciated if ICANN's Compliance Department could tell us exactly how many domain name registrations were terminated as a result of inaccurate data over the course of the last year. I leave it up to the ALAC to decide whether user concerns about WHOIS Data Accuracy and the WDPRS will be formally investigated by the ALAC, or whether the ALAC will sit on the sidelines while others do what has to be done. Danny