[comments-whois] Go Daddy's Comments on the Whois TF Interim Report
We certainly appreciate the time and effort that the Task Force has put in to compiling this report. However, we believe the recommendations presented reflect a lack of sufficient feedback from the parties that will be most affected by them and the parties that will pay the cost of their implementation, the registrars and registries.
For example, we take exception to the statement in the report that "...registrars have not established clear enforcement mechanisms to ensure their customers (resellers, ISPs or end-users) provide accurate data." No one at Go Daddy Software has been contacted in regards to this issue. If the task force has done research on this issue, we would ask that such research be provided with the report.
The report also refers to "commonly available automated mechanisms to screen out obviously incorrect contact data." There is nothing in the report to indicate that the Task Force considered the cost of these tools, and the problems associated with the accuracy of these tools themselves. Zip codes, area codes, etc. change frequently and our experience has been that these tools are not always up to date. Pinging email domains, automating the dialing of phone numbers, etc. have another set of technical obstacles and costs that make them impractical to implement and unreliable.
The report also implies that it would be appropriate that only North American registrars should be required to implement such costly tools. We strongly disagree. We do not believe the use of such tools will increase the accuracy of the data significantly enough to warrant the additional costs, most of which will no doubt be passed on to the consumer.
The 15 day timeframe within which to verify the data is not long enough. There are many legitimate reasons why a registrant is not reachable. They may have simply moved from one state or province to another. With all that's involved in such moves it is not hard to understand how they may overlook updating the contact data associated with their legitimately registered domain names. And remember, registrars deal with these issues Internationally. We suggest that a 45 day period is much more reasonable. The goal should be to protect the registrant's interests and get the data updated.
In light of the sanctions that the report is recommending, we would ask that "willful" and "blatant" be clearly defined. It may be clear to North Americans that the phone number 555-555-1212 is blatantly false. However, in most cases "blatant" and "willful" will be a very subjective call. Such a vaguely defined policy will be difficult, if not impossible, to enforce.
We believe the "3 Strikes Policy" is unnecessary. The current RAA simply needs to be enforced, and ICANN has recently been working toward that goal.
We would also like to add our support to the comments and recommendations made by Michael Palage on October 22, 2002 and posted at:
In conclusion, we believe there is much the Task Force has yet to consider regarding the implementation and effectiveness of their recommendations before making this report final.
Go Daddy software, Inc.