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[comments-whois] Re: [registrars] Public comment period on WHOIS TF final report untill 14 August

Comments respectively submitted:

1. Accuracy of the data contained in the WHOIS database:
It is simple to say that Whois data accuracy needs to be enforced. However, registrar enforcement of accuracy is no simple matter. If there are going to be possible sanctions and financial penalties imposed on Registrars, then there needs to be an extremely specific understanding of what "accuracy" means, an equally precise definition of what constitutes a reasonable effort on the Registrar's part to ensure that accuracy, and what steps the Registrar may take, without repercussions, when inaccuracies are found.
2. Uniformity of data formats and elements across various TLDs and registrars, including ccTLDs:
We agree. Also, uniformity of formats would certainly improve the end user's experience when trying to move their domains between registrars. However, we see no reason to put this off for a separate discussion. The data elements required for Whois are finite and specific. How difficult can these be? Only as difficult as those actually opposed to this idea want to make it. I suggest this be pursued immediately, as part of this recommendation, for gTLDs. ccTLDs can wait for a separate deliberation. Uniformity of data would also better support efforts to monitor the accuracy of that data.
3. Better searchability:
One primary reason for problems here is the issue discussed in 4 below.
4. Better protection of data subjects from marketing use of the data contained in the WHOIS database:
I think the recommendations made in the first bullet are no-brainers.
On the second bullet, use of the Whois data for marketing purposes of any kind, no matter how it is acquired, should be prohibited, unless they have a verifiable EXISTING business relationship (perhaps within the last 12 months). By allowing a PRIOR business relationship, you give the largest Registrar, a prior monopoly, an unfair advantage. The registrant should not have to "opt-in" or "opt-out". The Whois data should never be viewed, used, or treated as a marketing list.
Tim Ruiz
Go Daddy Software, Inc.

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