[comments-whois] Response to Task Force Interm Report

[Rick Wesson <wessorh@ar.com>]

Alice's Registry, Inc. Comments on Whois Task-Force
Interim Report of the Names Council's WHOIS Task Force October 14, 2002

Data Accuracy

   Alice's Registry, Inc. recently launched a new product to assist
   registrars in evaluating the accuracy of registrant data. Our
   research indicates that the vast majority of domain registrations
   don't have accuracy issues. In the near future we hope to bring
   some statisticly significant research to prove this general
   hypothesis. You can read more about our Fraud detection and
   Registrant Verification system at http://www.ar.com/fraudit/

   The proposal of graduated sanctions is not well thought out and
   appears to have been developed without industry participation. We
   feel that this would have never made it into a document developed
   by all concerned stake holders.

   At the time the document was authored there existed no
   methodology to test the assertion that graduated sanctions could
   improve the accuracy of the data published in the whois, now there
   are services to test this assertion; however there is no
   infrastructure within ICANN to preform such a audit. If the
   task-force continues to believe in such recommendations the
   task-force should also make clear proposals on how the
   recommendation should be implemented.


Uniformity of data elements

   A least common denominator of uniform elements should not prevent
   industry innovation.


Searchability

   Full searchability of the whois has been mistakenly identified as a
   service that previously existed. The task-force appears to have
   been misguided by interests looking for additional FREE services
   that have never existed.

   Mandating the creation of new FREE services should be done with a
   critical eye, as market forces applied with appropriate fee-based
   incentives appear to work in many industries instead of mandating
   free and unfettered access to new services.


Privacy

   The single most talked about topic with whois is privacy, the
   task-force has neglected this topic. Privacy impacts each of the
   areas discussed above. If the task-force continues to ignore
   privacy, all of the task-force recommendations will be circumspect.

   The fact remains that the largest use of whois is for marketing
   purposes, the task-force MUST address this issue in its final
   report.


Rick Wesson
CEO, Alice's Registry, Inc.