[comments-whois] Comments on Accuracy and Bulk Access Report

[Alexander Svensson <alexander@svensson.de>]

Comments on the 
Whois Task Force Accuracy and Bulk Access Policy Report
(http://www.dnso.org/dnso/notes/20021130.NCWhoisTF-accuracy-and-bulkaccess.html)


3.1.I.B.1.
While a functional definition of "inaccurate" or "unreliable" -- based 
on the actual usability of contact details -- is the right approach,
further clarification is needed, e.g. whether a registrant must be
reachable through all means of contact all the time.


3.1.I.B.3./3.1.IV.A.
I strongly support the dissenting opinion of the GA representatives
concerning the 15 day period. This period should not be the primary
means to stop overtly fraudulent websites as this is a task which
should be left to law enforcement authorities. Therefore, the period
should be extended. In addition, a hold period before the eventual 
deletion (as discussed in 3.1.IV.A.) should be considered. The 
experiences which will be gained by the introduction of the 
Redemption Grace Period (i.e. how many scheduled deletions will be 
averted) should help considering the value of such a hold period.

As to postal delivery, the Task Force is urged to consult
http://www.atlargestudy.org/stats/returned_letters.shtml (not a
final count) -- the postal service is not too reliable in all
countries and there are additional problems with regards to
addresses in Latin characters in countries with a different
alphabet. 


3.2.II.A.
I strongly agree with the recommendation to eliminate the use of bulk 
access WHOIS data for marketing purposes and the consideration of an
enforced restriction of bulk access to a well-defined group of 
legitimate users, respecting applicable national laws.


Best regards,
/// Alexander