Submission #: 2150

ID#: 996166760; Language: english

1. Category: governmental

Size of Organization: 90,000

2. Registered any domain names? yes

How many ccTLD registrations? 1; How many gTLD registrations?

Purpose of registrations: governmental

3. How often use Whois? hourly

4. Most important use(s) of Whois: responsibility

5. Purpose of Whois service

availability	similarity	merchants	IP	spam	illegal	other
	5	1		4	2	3

Description of "other" (if applicable): To identify domain names that have related registrants.

6: Primary concern: Other:We are concerned with having access to accurate information regarding the registrants of business domain names.

7. Ever harmed by bad Whois data? yes

What percent of data is inaccurate? 5-25

Description of harm: In a sample of 1,600 comercial web sites,we were unable to identify 12% of the beneficial owners of the web sites and determine if they were compliant in regard to their Federal Tax obligations. We were unable to associate the registrant and administrative contact information with an actual person or business.

How to improve? 1)More robust documentation standards.

2)A complaint or hotline system whereby the registrar could be notified of errors in the database for resoltion with the registrant.

8. Usefulness of gTLD data elements: inadequate

If "inadequate" or "unnecessary," what to drop/add: 1) Beneficial ownership of the domain name must be disclosed.

2) An indicator that the registrant has registered other domian names.

9. Need for data elements:

Domain Name	IP Address	Nameserver	Registrar	Created
essential	essential		essential	essential
Expires	Registrant	Tech	Admin
essential	essential	essential	essential

10. Allow searches on data elements other than domain name? yes (If yes, which elements? Domain Name Nameserver Registrant Tech Admin

Should Whois provide enhanced search capabilities? (If yes, who pays?) yes The costs should be funded out registration fees.

11: Use ccTLD Whois? yes

12: Should ccTLDs provide same elements as gTLD Whois? (Why or why not?) yes Uniformity in data elements is critical in order to prevent arbitrage transactions whereby registrants seek to use ccTLDs in order to avoid the more robust documentation/disclosure standards imposed on registrants of.com names.

13. Should Whois format and services be uniform? (How to achieve?) yes ICANN must develop an consensus within the Internet community that more robust documentation standards and know your customer rules will benefit all stakeholders. This consensus can be formalized in the ccTLD registrar agreements.

14. Support centralized Whois access? yes; Across .com/.net/.org? yes

Across all gTLDs? yes; Across all TLDs? yes

Best way to achieve centralization? ICANN as a facilitatior should incorporte the requirment inot its ccTLD registration agreements.

15. Who should pay for centralized access? registrants

16. Should registrars be allowed to sell contact information? opt-in

17. Maintain gTLD bulk access provisions? ; Extend provisions to other gTLDs?

Welcome commercial e-mail from service provider? no

Should bulk access provisions be changed? (If so, how?) yes The policy needs to differencciate between individuals engaged in commercial and non-commercial activities.

18. Question for registrars: offer third-party registration?

19. Question for public: use third-party registration?

20. Final comments: We would like to reiterate that "know your customer rules" and transparency in the matter of commercial domain name ownership are paramount to tax administration.