[nc-whois] Additional Comments from the gTLD Registry Constituency

["Karen Elizaga" <karen@elizaga.name>]

Fellow Task Force Members:

This is my last posting as a member of the Task Force, and I just have to say now what a pleasure it has been working with the group.  I wish you much luck in moving the efforts of the Task Force forward.

The following are additional comments from the gTLD Registry Constituency on the drafts that have been circulated on Accuracy and Bulk Access and proposed to comprise parts of the Final Report.  The gTLD Registry Constituency appreciates the extent to which its previous statements have been heard and incorporated by the Task Force and will reserve the right to make additional comments to the Final Report once it is posted.

Please contact either Ram Mohan or Fran Coleman for further feedback from the constituency.

Regards.
KE

Accuracy:

The following recommendation interesting: "(3) ICANN should post
registrar contact points on its web site."  There should be very careful
movement forward on this, if any, as there will likely be many problems
with its implementation.


Section 5b of the accuracy document describes a registrant response period
of 15 days.  As we've discussed before, this is bound to be insufficient in
cases where international postal mail is involved in contacting the
registrant.  At least the issue is acknowledged in section 5c with a
recommendation to see how well 15 days works, but it is probably a betters
 cenario where a longer period (30 days) be initially recommended.

Recommendation 5 would probably require a trouble ticketing system to do
effectively.

Bulk Access:

The recommendations still seem impossible to enforce but we appreciate thee
 mphasis on considering eliminating bulk access requirements.

Legitimate need? As noted in the document the definition of legitimate needs
to be determined.  It needs to be clearly defined in a measurable way and
that will not be a trivial task.  The report gives these examples:
"research, law/intellectual property enforcement, and registrant inquiry,
etc."  What kind of research?  Is market research okay as long as it doesn't
result in marketing?  Who has the right to enforce intellectual property
rights and thereby the right to bulk access?  What does registrant inquiry
mean?  It's hard to imagine that registrants would need bulk access.

The Task Force should tread very carefully on issues relating to "cost recovery."  
What legitimate business wants others looking at their books to tell them what 
they can charge?  


Karen Elizaga
Vice President - Policy
Global Name Registry
125 High Holborn
London WC1V 6QA UK
Tel:  +44 (0)20 7025-2231
Mob:  +44 (0)7740 871-698
Fax:  +44 (0)20 7242-9105
Email:  karen@elizaga.name  
Web:  www.name



Information contained herein is Global Name Registry Proprietary Information and is made available to you because of your interest in our company.    This information is submitted in confidence and its disclosure to you is not intended to constitute public disclosure or authorization for disclosure to other parties.
*****************
What's your .name?
Get one at www.name
*****************