[registrars] FW: Whois task force recommendations

["Michael D. Palage" <michael@palage.com>]

Attached please find a thoughtful and well reasoned submission that Directi
submitted to the Whois Task Force. These kinds of constructive comments are
important to get on the record. It is important that when submitting
comments that they be constructive (not destructive). We need to be viewed
as being part of the solution, not part of the problem.

It is also important for non-US based registrars to provide input on their
national laws and other considerations regarding your customers, i.e. delays
in postal deliveries, telecommunications problems, etc.

Best regards,

Mike



-----Original Message-----
From: Bhavin Turakhia [mailto:bhavin.t@directi.com]
Sent: Wednesday, November 06, 2002 6:21 AM
To: comments-whois@dnso.org
Subject: Whois task force recommendations


Hi,

I represent Directi. We are an ICANN Accredited Registrar. It has been a
hectic week after returning back from the icann meeting at shanghai.
Firstly I must commend the Whois Task force on the significant effort
put in which is quite visible from the final report. The report though
comprehensive however has flaws which I believe exist due to lack of
feedback from the party that will have the maximum effect by its
implementation - namely us registrars.

Its funny however that if there was one thing that there was a
significant consensus about in the registrar meetings, it was with
respect to these flaws in the whois task force recommendations. Several
of the proposals made out by the task force seem quite unrealistic or
not feasible. For instance - we all know that invalid whois data needs
to be rectified. However the very reason for icanns existence, is to
ensure that no genuine party gets affected and no genuine domain name
holder loses out in any process. It is important to note that NOT
CONTACTABLE within 15 days would in no way represent inaccurate. We as
registrars know there have been so many situations created where
registrants have been incontactible. Infact large effects are felt when
large email providers shut business. So many registrants still have a
@usa.net address listed in their whois information which no longer
works. There have been countless email providers who have shut down and
their effects on accuracy and contactibility of registrants is something
we as registrars have faced invariably. It takes longer than 15 days for
a letter to reach the right hands of a registrant. So many registrants
have assigned their domain to contact persons within their organisations
that do not exist anymore. It would be draconian to delete a name just
because someone is incontactible for 15 days. A 45 day contacting period
is far more appropriate, and even after that the domain must not be
deleted, but be placed on registrar-hold so that a genuine registrant
may realise and contact the registrar directly. Even verisign offers a
45 day auto-renew period to ensure a registrar can within that timeframe
contact the registrant and obtain a confirmation for the renewal. I can
imagine the chaos we as registrars would face if verisign cut down the
autorenew period to 15 days within which we would have to confirm a
renewal or delete the name.

There are various such points which from a registrars perspective since
we are out there dealing with customers on a daily basis - seem quite
unfeasible to implement. Instead of listing them all down - I would
actually like to refer to the points laid out by Michael Palage in his
document -

http://www.dnso.org/dnso/dnsocomments/comments-whois/Arc01/msg00012.html

The comments listed by Mike are exhaustive and cover all the aspects I
believe need to be modified or rethought.

I would urge the task force to take a relook at these and other points
that other registrars may raise.

Thanks
Best Regards
Bhavin Turakhia
Founder, CEO & Chairman
Directi
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Tel: 91-22-6370256 (4 lines)
Fax: 91-22-6370255
http://www.directi.com
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