I know we came to a decision at the Dakar meeting on Proxy registrations but I have been giving this a lot of thought since then. I am uncomfortable with not addressing best practices for proxy registrations. I agree with the argument that a registrar does not have knowledge of the contractual agreement between the proxy service and licensee (or in my view the "true" registrant) if there is no relationship between the proxy service provider and the registrar. For instance, I may request a law firm to register a domain name on behalf of Facebook. The registrar does not have any idea what contractual agreement exists between Facebook and the law firm. A registrar that has a subsidiary set up to provide proxy service or enters into a partnership and recommends a proxy service at the time of registration does have knowledge of that contractual agreement and should be held responsible for the enforceable requirements that we outlined for privacy registrations. I would recommend that a registrar would be required to disclose their relationship with a proxy service provider to ICANN and that proxy service would have to adhere to the enforceable requirements through the registrar's accreditation. The reality of the proxy services is that most are provided by companies that are either a subsidiary of a registrar or in a partnership with a registrar. If we ignore this growing trend of proxy registrations then proxy registrations will continue to significantly impact the accuracy of the WHOIS data. Domains by Proxy runs a responsible and responsive proxy service we should insure that all registrar run proxy service providers provide the same high level of service. Good luck tonight. Susan Kawaguchi Domain Name Manager Facebook Inc. 1601 California Avenue Palo Alto, CA Phone - 650 485-6064 Cell - 650 387 3904 Please note my email address has changed to skawaguchi@fb.com NOTICE: This email (including any attachments) may contain information that is private, confidential, or protected by attorney-client or other privilege. Unless you are the intended recipient, you may not use, copy, or retransmit the email or its contents.