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

["Abel Wisman" <abel@able-towers.com>]

Karen, 

Said to see you go, hope you will do well in the new circumstances, it
has been a pleasure working with you, and maybe, seeing as we are not
that far apart we can meet up for a drink one of these days.

As for the comments of the registrars, my comments on that in between
the line: (MY opinion)

-----Original Message-----
From: owner-nc-whois@dnso.org [mailto:owner-nc-whois@dnso.org] On Behalf
Of Karen Elizaga
Sent: 29 November 2002 17:41
To: nc-whois@dnso.org
Cc: gtld-planning@nic.museum
Subject: [nc-whois] Additional Comments from the gTLD Registry
Constituency


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.
<comment>
"there will likely be many problems with its implementation" is not a
very well funded comment. Where it is expected from the TF that
proposals are foudned on facts, the TF will need input that is
accompanied by facts to consider these implications. 
O can see a hightened mail activity towards the registrar, but no other
probles for starters and hence do not see why the movements should be
carefull.
</comment>

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.
<comment> see my dissenting position on the topic, I couldn't agree more
and think even 45 days would be far more realistic. </comment>

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

<comment> something most registrars should have in place anyway, and
available under open source</comment>

Bulk Access:

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

<comment>The recommendation is to abolish the bulk access, at least for
marketing purposes, preferably completely as far as I am concerned (and
afaik most TF members)so that would solve a lot of enforcement problems.

</comment>

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.

<comment> Again, my opinion, remove all of bulk-access and be done with
the possible problems, in every day life the IPC and Law enforcement
community have far bigger hurdles to surpass in "finding" cullprints, or
identifying them, those "hurdles" are mostly there for a reason,
protecting the innocent and safe-guarding the democratic part of the
world.
I fail to see why on a network such as the internet, we all of a sudden
should get rid of those safeguards and open all databases to those who
seek the info and claim to have a legitimate reason.
Defining "legitimate use" will be an interesting task for the TF and
council should it ever come to that. </comment>

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?  

<comment>If changes in the RAA have a cost effect on registrars that
goes above their current cost-patern, then they should have a right to
discover the cost, and in order to protect the millions of users and
clients, setting these cost-recovery increases to rules is not a thing
out of this world, it is something most telco's will be knowledgable
about, as will many other companies, again, this is not a different
world with new rules, if changes cost, the cost should be recovered,
they should not be the legal excuse for price increases that are not
founded by higher cost. If it is that hard to share proof of those cost,
then the cost can not be that significant that they merit a price
increase to begin with.
</comment>

With kind regards

Abel Wisman
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