Name Intelligence, Inc. 12806 SE 22nd PL · Bellevue, WA 98005 August 5, 2004 VIA EMAIL Attention: Paul Twomey and Bruce Beckwith Public Interest Registry 1775 Wiehle Ave, Suite 102A Reston, Virginia 20190 Phone: +1-703-464-7005 Facsimile: +1-703-464-7006 RE: PIR’s EPP DOMAIN INFO command change announcement Dear Paul Twomey and Bruce Beckwith, Name Intelligence, Inc. has just been made aware that PIR will be modifying its Dot ORG Registry Software to be non-compliant with EPP1.0. They are moving away from full complacence with EPP 1.0’s DOMAIN INFO command. Their announcement is that they will stop providing complete information according to RFC 3732. Their intention is stop showing all information except for Registrar of record. The reason is to make the command thinner and prevent data mining. However NO registrant information is even being returned with this command right now. The “INFO” command is already a thin command that shows very little information. The information that it does show is fields like: Domain Name, Registrar of Record, Domain Status (On-hold, Transfer-prohibited, Registrar-lock), Domain Creation Date, Modification Date, Expiration Date. We need these fields for our domain suggestion software that appears on NetworkSolutions.com, GoDaddy.com, Enom.com, Yahoo, and lots of other registration company’s websites. This software helps millions of people a year to register domain names. PIR’s impact on our business and that of our customers would be overwhelming if their stated changes takes place. Even VeriSign which operates a thin Registry would be showing more information then PIR after PIR’s EPP change. PIR limits their whois access more severally then VeriSign does. Therefore gathering Domain Status and expiration date is very complex with PIR. With VeriSign we just query for this using their whois and we get the answer back. We tried this approach with PIR but they banned our IP addresses because they said we requested too many records. I am not sure if that was fair and equal for them to do since we sevice millions of customers a day, but that is the primary reason our company sought accreditation as an ICANN Registrar. Querying via the EPP command instead of whois allows us access to the same information which is critical to the operations of our company. Actually, the info command returns less information then whois. But having got accredited just for EPP domain info command and now using EPP to gather this information we later hear that PIR is going to begin hiding domain’s status and expiration date from the DOMAIN INFO command. Our business relies on this EPP command to determine the domain’s status and expiration date and we use these values in our suggestion software. We formally request that PIR repeal their decision on hiding expiration date and status from the DOMAIN INFO command. And we also formally request that ICANN enforce their contract with PIR and make them stay complaint with EPP 1.0 (RFC3732) for the DOMAIN INFO command. PIR has stated several times that they wish to be the model registry, yet this move by them would make them even worse then VeriSign as far as usability. It would degrade the registration process of millions of users annually. Suggestions for available domain names is a service that users rely on and expect in a good registrar. PIR would force our software to be less accurate and possible suggest a .ORG domain that is already registered. And in my option that is a move in the wrong direction for this registry. Helping us help the registrars with registration is where I want to see PIR headed. http://www.icann.org/tlds/agreements/org/ http://www.faqs.org/rfcs/rfc3732.html Sincerely, Jay Westerdal President and CEO Name Intelligence, Inc. CC: Dan Holloran, Registrars