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[comments-whois] Time Inc. Comments

	Time Inc. ("Time") is pleased to provide the following comments in
response to the "Interim Report of the Names Council's Whois Task Force".
Time is the publisher of People, Time, Sports Illustrated, Fortune and over
100 other magazines and appreciates the work of the Task Force and supports
many of the recommendations contained in the Interim Report.

	Accurate, reliable and easily accessible "whois" data is essential
to the effective transfer and enforcement of trademark rights. In this
regard, legitimate uses of  "whois" data include (i) carrying our legal
audits of property rights; (ii) conducting due diligence in acquisitions and
mergers; and (iii) the enforcement of trademark rights; and (iv) the
clearance of new trademarks.

	Accordingly, Time supports the following recommendations:

	A.  Accuracy of Information

	    1. Requiring that Registrars use commercially available
automated mechanisms to screen out obviously incorrect data;

	    2. Requiring that Registrars cancel registrations whose contact
data reflects the "willful provision of inaccurate or unreliable

	    3. Requiring that Registrars demand verification of "corrected"
data supplied by a registrant that has previously deliberately provided
	        incorrect data; 

	    4. Requiring that Registrars handle all registrations based on
the same false data together; 

	    5. Recommending that ICANN revise the RAA to require Registrants
to review and revalidate "whois" data upon renewal of the 
	         registration; and

	    6. Recommending that ICANN take action against all gTLD
Registrars who fail to take steps implement points 1-4 above. 

	B.  Uniformity of Formats

	     1. Requiring that all "whois" data be uniform, consistent and
complete across all gTLDs and ccTLDs; and

	     2. Recommending that ICANN take action against all Registrars
who fail to provide uniform, consistent and complete "whois" data
	         which is easily accessible to the public.

	C.  Better Searchability

	      1. Registrars should provide for a broader menu of
searchability, for example, by Registrant; and

	      2. "whois" data for all gTLDs and ccTLDs should be made
available to the public. 

	Respectfully Submitted,

	Robert T. Scherer
	Senior Counsel
	AOL Time Warner Inc.
	on behalf of Time Inc.




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