[nc-whois] Comments from Chuck Gomes, VGRS
Comments from Chuck Gomes, VGRS are listed
----- Original Message -----
Sent: Wednesday, July 17, 2002 12:46 PM
Subject: Re: [GTLD-RC] Fw: [nc-whois] Public comment period on WHOIS
TF fi nal report untill 14 August
note my comments below.
Accuracy of the data contained in the WHOIS
The Task Force
believes that the approach of actually enforcing the existing contractual
provisions is the essential first step toward improving WHOIS data accuracy in the gTLD
The Task Force
believes that a method of graduated sanctions or enforcements against
parties who breach the requirement to provide accurate information and to
maintain an accurate Whois database, potentially as a combination of policy
and financial penalties, should be considered, in order to facilitate the
actual enforcement of the current policy with respect to WHOIS data
If enforcement of current
contractual provisions does not
lead to an improvement of WHOIS data accuracy, then more substantial changes
to the RAA itself or the establishment of consensus policies (as necessary)
should be considered.
[Gomes, Chuck] Enforcing the requirement to
have a Whois service and that it follow an agreed to format is one
thing. Enforcing accuracy of data is quite another. I personally
do not think it is realistic. Note that it really does not impact us as
a thin registry, but it could have huge cost implications on registrars and
probably thick registries.
2. Uniformity of data formats and
elements across various TLDs and registrars, including ccTLDs
The Task Force
believes that the questions of uniform data formats and uniformity of data
elements need to be discussed and handled
The present Task Force believes that the use of such a uniform data
format across gTLD and ccTLD environments should be
The Task Force believes that
WHOIS data elements should be uniform across all
[Gomes, Chuck] How about encourage voluntary
compliance for ccTLDs?
The Task Force believes that this topic should be the
subject of separate deliberations.
These deliberations should take into account specific aspects of the TLD environments, as well as the
value of accountability and
transparency across the domain name system. Public interest concerns
should be taken into account in an appropriate manner. The objective should be to identify the
best way to make progress toward the goal of the uniformity that all users of the system clearly
To facilitate the
restoration of full searchability of Whois databases [see (1) and (2) above],
ICANN should explore both
enforcing the mandate to registrars and registries to provide
(or to cooperate in the provision of) such complete WHOIS search service, and a
market-based approach based on bulk access to WHOIS
[Gomes, Chuck] This again
raises serious feasability and cost implications for registrars and thick
With respect to the more advanced services described in (3)
above, the Task Force does not recommend any policy changes. The Task Force
suggests that ICANN explore how best to swiftly develop and implement a plan for cross-registry
Whois services, including through
third party services, based on bulk access to WHOIS data.
4. Better protection of data subjects
from marketing use of the data contained in the WHOIS database
Based on these results, the Task Force recommends a
review of the current bulk access provisions of the Registrar Accreditation
particular, the following possible changes should be examined more
The policy could attempt to ensure that
protection mechanisms can't be circumvented by third parties selling
indirect access to bulk data.
This could, for instance, be accomplished by changing "may require"
in section 22.214.171.124 to "shall require."
It could also be accomplished by requiring bulk access users to impose conditions on the
use of their products and services which are similar to the ones in ICANN's
Sections 126.96.36.199 (prohibition of use of bulk access
data for marketing purposes) and 188.8.131.52 (opt-out provision) could be
simplified, unified, and
extended to include contact data of organizational entities. Marketing use
of registrants' data outside existing business relationships could depend on
the registrant's prior agreement ("opt-in").
[Gomes, Chuck] Current bulk data access
requirements are nearly impossible to