DNSO Working Group C:
SIIA wishes to express its support for the cautionary points raised by Caroline Chicoine regarding the proposal to add new gTLDs. At present there exist several unresolved issues regarding the present gTLDs and adding new ones to the fold while these issues remain unresolved is unwise. SPA Anti-Piracy, a division of SIIA, utilizes mechanisms such as WHOIS to help us ascertain the identity of site-operators and/or Internet Service Providers. Prior to the commercialization of the DNS, we only had to turn to NSI to obtain contact information about a particular URL. With the advent of so many new DN registrars, we face serious issues regarding access to WHOIS information via these new registrars.
Last Fall, the Copyright Coalition on Domain Names sent a questionnaire to all of the new registrars asking them about what type of WHOIS mechanisms they maintained as well as their respective contact points. The disappointing response level that we received (only 1 registrar bothered to respond with any substantive information) causes us great concern. These new registrars are required, by the accreditation agreements that they signed with ICANN, to provide a reliable WHOIS service so that the general public, copyright owners, and organizations that represent copyright owners, can have recourse against website that are offering infringing material. ICANN must ensure that these registrars are complying and meeting their obligations. A registrar that does not ensure the collection of reliable contact information can easily become a safe haven for pirates, as they know that they will be able to supply bogus contact information without fear of punitive action.
SIIA strongly believes that these problems must be fully and exhaustively addressed. Setting up new gTLDs in places where the registrars are not collecting reliable information about the registrant, or are not providing adequate access to that information, will expand an already vexing problem. ICANN, and its constituent working groups, must work to ensure a robust, responsive WHOIS system in the present .com, .net, and .org domain name communities. When this has been done, and when the problems of site identification have been addressed within the existing system, then we would support adding new gTLDs to the fold. However, until concerns with the new registrars are ironed out, we must express our disapproval of adding new gTLDs at this time.
Mike Flynn (email: email@example.com)
Manager of Internet & International Anti-Piracy
Software Publishers Association
a division of software & information industry association
1730 M Street NW
Washington, D.C. 20036-4510
ph: 202 452 1600, ext 366
fax: 202 223 8756