[comments-whois] Go Daddy's Comments on the Whois TF Interim Report
We certainly appreciate the time and effort
that the Task Force has put in to compiling this report. However, we believe the
recommendations presented reflect a lack of sufficient feedback from the parties
that will be most affected by them and
the parties that will pay the
cost of their implementation, the registrars and
registries.
For example, we take exception to the statement in
the report that "...registrars have not established clear enforcement mechanisms
to ensure their customers (resellers, ISPs or end-users) provide accurate data."
No one at Go Daddy Software has been contacted in regards to this issue. If the
task force has done research on this issue, we would ask that such research be
provided with the report.
The report also refers to "commonly available
automated mechanisms to screen out obviously incorrect contact data." There is
nothing in the report to indicate that the Task Force considered the cost of
these tools, and the problems associated with the accuracy of these tools
themselves. Zip codes, area codes, etc. change frequently and our experience has
been that these tools are not always up to date. Pinging email domains,
automating the dialing of phone numbers, etc. have another set of technical
obstacles and costs that make them impractical to implement and unreliable.
The report also implies that it would be
appropriate that only North American registrars should be required to implement
such costly tools. We strongly disagree. We do not believe the use of such tools
will increase the accuracy of the data significantly enough to warrant the
additional costs, most of which will no doubt be passed on to the
consumer.
The 15 day timeframe within which to verify the
data is not long enough. There are many legitimate reasons why a registrant is
not reachable. They may have simply moved from one state or province to another.
With all that's involved in such moves it is not hard to understand how they may
overlook updating the contact data associated with their legitimately registered
domain names. And remember, registrars deal with these issues Internationally. We suggest that a 45 day period
is much more reasonable. The goal should be to protect the registrant's
interests and get the data
updated.
In light of the sanctions that the report is
recommending, we would ask that "willful" and "blatant" be clearly defined. It
may be clear to North Americans that the phone number 555-555-1212 is blatantly
false. However, in most cases "blatant" and "willful" will be a very subjective
call. Such a vaguely defined policy will be difficult, if not impossible, to
enforce.
We believe the "3 Strikes Policy" is
unnecessary. The current RAA simply needs to be enforced, and ICANN has recently been working toward that
goal.
We would also like to add our support to the
comments and recommendations made by Michael Palage on October 22, 2002 and
posted at:
In conclusion, we believe there is much the Task
Force has yet to consider regarding the implementation and effectiveness of
their recommendations before making this report final.
Tim Ruiz
Go Daddy software, Inc.
|