Dear Colleagues,
 
Thanks to you both for your comments on the recommendations. I agree with all of the proposed questions, and have a few additional thoughts relating to the accuracy recommendations (recommendations 6 and 7).
 
The purpose of recommendations 6 and 7 appears to be to improve the accuracy of WHOIS data over time, with a particular focus on the most inaccurate data (i.e. that which does not allow contact to be made with the registrant). This level of inaccuracy is a major problem for many stakeholders, including governmental law enforcement agencies who investigate serious crimes. Another important aspect of this issue relates to the need to collect reliable data on WHOIS accuracy levels, to allow ICANN (and the community) to assess the impact of any reforms it introduces, any ramp up of its compliance efforts, and so on.
 
In response to these recommendations, the Board directed the CEO to begin proactively identifying potentially inaccurate data registration information, explore the use of automated tools, and forward on any potentially inaccurate records to registrars for correction. The Board also directed the CEO to produce public reports on these resulting actions, to encourage improved accuracy of WHOIS data.
 
Following the Board’s response, ICANN staff appear to have focused on a number of initiatives (as outlined in the report), but it is not clear that their activities directly tackle the issue identified by the review team – i.e. the need to reduce the level of grossly inaccurate data, and to actively track progress with that. In fact the staff response appears to effectively say that they cannot measure this information, because it cannot be achieved via an automated solution. It may be that this is an acceptable response, but given the importance of the issue for many stakeholders, and for ICANN itself, I would be interested to ask staff:
 
•             Does ICANN believe that the proposed implementation approach responds fully to the recommendation?
•             Does ICANN believe that the proposed implementation approach responds fully to the Board’s decision?
•             If the staff believe that their proposed online process will provide the same results as contemplated in the recommendations, could they please provide more information on this, and how ICANN will use it to improve, monitor and transparently report on the accuracy of WHOIS data?
·                  As Alan has already highlighted, if ICANN does not believe that the recommendation can be implemented as is, what alternative do they suggest to address the spirit of the recommendation?
 
Kind regards
 
Stephen Conroy
 
 
From: workstream3-atrt2-bounces@icann.org [ mailto:workstream3-atrt2-bounces@icann.org] On Behalf Of Michael Yakushev
Sent: Monday, 17 June 2013 11:35 PM
To: Alan Greenberg
Cc: ATRT2 WS3
Subject: Re: [Work Stream 3 ATRT 2] Suggestions for addition information requests
 
Dear Alan, colleagues,
 
I am very thankful to Alan for this comments/suggestions/requests. To be frank, I was much more polite with my own assessment of the current developments with the implementation of WHOIS RT procedures.
I do agree with all the proposed suggestions. I have to admit that I missed very important issue, mentioned by Alan in Item 9 ("The WRT recommendation as stated is not feasible.”etc.). This unfortunate situation really needs clarification.
May I also add a question in the table, prepared by Alan - re Recommendation 13. The staff indicated that they are still 'awaiting GNSO policy on translation or transliteration', while Recommendation 12 suggests that 'ICANN should task a working group' on such issues. The update/clarification is needed.
 
I fully agree that we need to have an updated feedback from the staff for the whole picture.
 
Kind regards,
Michael
 
 
2013/6/17 Alan Greenberg <alan.greenberg@mcgill.ca >
Please find attached my suggestions for the request for additional information.

Alan
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