Re: [registrars] .US Update

["Ross Wm. Rader" <ross@tucows.com>]

> Ross, I don't necessarily agree with that statement.
<snip>
> I'm not confident that any alternative solution will be quickly
forthcoming.
> I believe the complaint form process is at least a workable interim tool
to
> help with enforcement.

Let me clarify a little bit further. I touched on this in our comments to
the Whois Task Force as well.

(Note: All numbers are for illustration purposes only)

Constants:
15 million existing dotCOM registrations
5 million existing records with dirty data
40,000 new record additions per day
10,000 new record deletions per day
1,000 complaints filed per day

If we assume that new data is just as dirty as old data, we are likely
adding at least 10,000 net new dirty records to the database per day. We are
only catching 1,000 per day. Even if the number of records with dirty data
is 10% of what I used above, the problem persists.

At this rate, in four years, the problem will, at best, be at least exactly
the same size if we continue to employ the same solutions. I expect that
this will hold true for dotUS as well.

> Issues involving how to get more accurate data up front are another matter
> entirely. I don't think we should confuse the purpose of the complaint
form
> process, enforcement, with improving the processes to collect more
accurate
> up front.

I propose that this is precisely where we focus our efforts. There is a
fallacy that Registrars are responsible for the accuracy of the data in the
Whois database. Registrars are only obligated to solicit the cooperation of
Registrants when the data is deemed inaccurate - and invoke penalties for
non-compliance. The responsibility for the accuracy of the data still
remains with the Registrant however. Until and unless we start to look at
how we can proactively incent Registrants to uphold their end of the
bargain, the problem will continue to exist - and given the nature of the
proposals that continue to come forward, our costs will continue to
increase.


                       -rwr




"There's a fine line between fishing and standing on the shore like an
idiot."
- Steven Wright

Got Blog? http://www.byte.org/blog
----- Original Message -----
From: "Tim Ruiz" <tim@godaddy.com>
To: "Ross Wm. Rader" <ross@tucows.com>; "Michael D. Palage"
<michael@palage.com>; <registrars@dnso.org>; "Elana Broitman"
<ebroitman@register.com>
Sent: Friday, November 08, 2002 3:48 PM
Subject: RE: [registrars] .US Update


> > very nature of the construct virtually prevents it from being effective
to
> any appreciable degree.
>
> Ross, I don't necessarily agree with that statement.
>
> Before the complaint form process, there was nothing in place to assist in
> the enforcement of maintaining accurate whois data. The proposals that
have
> been put forth by the Whois TF after months of work are out of touch with
> the day-to-day reality of doing business.
>
> I'm not confident that any alternative solution will be quickly
forthcoming.
> I believe the complaint form process is at least a workable interim tool
to
> help with enforcement.
>
> Issues involving how to get more accurate data up front are another matter
> entirely. I don't think we should confuse the purpose of the complaint
form
> process, enforcement, with improving the processes to collect more
accurate
> up front.
>
> Tim
>
>
> -----Original Message-----
> From: owner-registrars@dnso.org [mailto:owner-registrars@dnso.org]On
> Behalf Of Ross Wm. Rader
> Sent: Friday, November 08, 2002 2:03 PM
> To: Michael D. Palage; registrars@dnso.org; Elana Broitman
> Subject: Re: [registrars] .US Update
>
>
> > My personal opinion is that it is never too early to start tackling
> > fraudulent data in a responsible manner. Failing to tackle the problem
> only
> > allows non-responsible parties to game the system to the detriment of
the
> > industry.
> >
>
> Agreed - but there is no conclusive information that demonstrates that an
> "Internic-complaint like" process will satisfy those objectives. To the
> contrary, I suspect that the very nature of the construct virtually
prevents
> it from being effective to any appreciable degree.
>
> > I believe that by being proactive, registrars could work with NeuStar
and
> > the rest of the .US stakeholders to develop mechanisms that work for all
> > parties involved.
>
> I couldn't agree more, but my primary concern with this recommendation is
> that it falls into the same trap that the Whois task force does - it
> increases the cost of transactions without any guarantee of achieving the
> stated goals. When my costs go up, I'd prefer to have some line-of-sight
to
> the benefits.
>
> My preference would be to explore alternate arrangements before we settle
on
> this sub-optimal solution. Neustar has a great opportunity to
progressively
> set itself ahead of the pack with policies of this nature. I'd hate to see
> arrangements of convenience mute this.
>
>                        -rwr
>
>
>
>
> "There's a fine line between fishing and standing on the shore like an
> idiot."
> - Steven Wright
>
> Got Blog? http://www.byte.org/blog
> ----- Original Message -----
> From: "Michael D. Palage" <michael@palage.com>
> To: <registrars@dnso.org>; <ross@tucows.com>; "Elana Broitman"
> <ebroitman@register.com>
> Sent: Friday, November 08, 2002 2:38 PM
> Subject: RE: [registrars] .US Update
>
>
> > There are approximately 400,000 registrations in the .US TLD according
to
> my
> > records.
> >
> > My personal opinion is that it is never too early to start tackling
> > fraudulent data in a responsible manner. Failing to tackle the problem
> only
> > allows non-responsible parties to game the system to the detriment of
the
> > industry.
> >
> > I believe that by being proactive, registrars could work with NeuStar
and
> > the rest of the .US stakeholders to develop mechanisms that work for all
> > parties involved.
> >
> > Again, these are my personal opinions as a legal and policy
representative
> > to the .US Policy Council.
> >
> > Mike
> >
> >
> > -----Original Message-----
> > From: owner-registrars@dnso.org [mailto:owner-registrars@dnso.org]On
> > Behalf Of Elana Broitman
> > Sent: Friday, November 08, 2002 2:02 PM
> > To: 'Michael D. Palage'; ross@tucows.com; registrars@dnso.org
> > Subject: RE: [registrars] .US Update
> >
> >
> > how many new .us registrations are there?  is it worth having a
reporting
> > mechanism at this point, or should we give the ICANN process some time
to
> > test the system?
> >
> > -----Original Message-----
> > From: Michael D. Palage [mailto:michael@palage.com]
> > Sent: Friday, November 08, 2002 10:27 AM
> > To: ross@tucows.com; registrars@dnso.org
> > Subject: RE: [registrars] .US Update
> >
> >
> > Yes basically I was advocating the use of a whois reporting mechanism
the
> > same as currently used by ICANN at the InterNIC site. Our next .US
Policy
> > call is next week and I will try to have a motion to submit although I
am
> > currently busy working on the kids.us component.
> >
> > Just to set the record straight, I am not the registrar representative
on
> > the .US Policy Council. That honor would fall on David Washer. My
position
> > is as a legal expert.
> >
> >
> >
> > -----Original Message-----
> > From: Ross Wm. Rader [mailto:ross@tucows.com]
> > Sent: Friday, November 08, 2002 10:14 AM
> > To: Michael D. Palage; registrars@dnso.org
> > Subject: Re: [registrars] .US Update
> >
> >
> > Michael,
> >
> > Can you provide the constituency with more details concerning this item
> from
> > the minutes?
> >
> > "Mr. Palage advocates adoption within .us of the WHOIS data accuracy
> gateway
> > policy and process adopted by ICANN.  Place the burden of data accuracy
> > appropriately on registrars and registrants.  He noted that FCC and DoC
> have
> > reacted positively to policy.
> >
> >
> > Mr. Hudis asked that Mr. Palage provide written proposal given
complexity
> of
> > item.  Mr. Palage noted that the motion basically would be that NeuStar
> > adopt and implement in a manner similar to ICANN.
> >
> >
> >
> > Ms. Tennant noted concern regarding the ability of individuals to speak
> > anonymously on the Internet and what impact the WHOIS policies have on
> this
> > right.  Mr. Palage noted that Go Daddy, an Internet registrar, offers a
> > WHOIS proxy product to address such concerns.  Mr. Casey noted that the
> > service was legal under the .US Registrar contract.
> >
> >
> >
> > Mr. Palage and Mr. Wascher agreed to draft a policy proposal and submit
it
> > to the counsel.  Mr. Hudis asked for the document by the end of
October."
> >
> >
> >
> > While this is a ccTLD issue and outside of the scope of formal policy
> action
> > of the DNSO and this constituency, details such as these have
significant
> > operational impact on the membership and advance notice of the proposal
> that
> > the council is considering would be useful to set the frame of reference
> for
> > many of the members. This is especially significant given the documented
> > policy flaws of the ICANN policy model regarding Whois.
> >
> >
> >
> >                        -rwr
> >
> >
> >
> >
> > "There's a fine line between fishing and standing on the shore like an
> > idiot."
> > - Steven Wright
> >
> > Got Blog? http://www.byte.org/blog
> > ----- Original Message -----
> > From: "Michael D. Palage" <michael@palage.com>
> > To: <registrars@dnso.org>
> > Sent: Friday, November 08, 2002 9:57 AM
> > Subject: [registrars] .US Update
> >
> >
> > > NOTICE OF PROPOSED CHANGES TO NEXUS DISPUTE POLICY AND RULES
> > > Notice of Proposed Changes. On October 8, 2002, the .US Policy Council
> > voted
> > > to post the following proposed changes to the .US Nexus Dispute Policy
> and
> > > Rules enabling a Complainant to recover a domain name if that domain
> name
> > is
> > > registered by a person or entity that fails to meet the usTLD Nexus
> > > Requirements and such failure to meet the requirements is not cured
> within
> > > thirty (30) days.
> > >
> > > Public Comment Invited. Public comment is invited on the proposed
> changes
> > to
> > > the Nexus Dispute Policy and Rules below. Comments should be sent by
> > e-mail
> > > to
> > > US-List-Admin@Neustar.biz no later than November 20, 2002.
> > >
> > > See http://www.neustar.us/policies/nexus_changes.html to link to the
> > > Proposed Changes
> > >
> >
>
>