Draft NCUC comments

[KathrynKL at AOL.COM]

This is great, Milton.  Chris, I am glad you raised the issue.
I think that Milton's words below echo our NCUC presentation in Tunisia,
and will make a terrific conclusion (opening?) to the comments I drafted.
Together we explain our concerns and then the alternatives that resolve them.
Not bad :-)  Kathy

<<If Whois data remains fully accessible on a public and
anonymous basis, we strongly favor the elimination of all
personally identifiable contact data as a required element
of Whois except for:

Registrant Name
Registrant Country of Residence

Technical Contact Name
Technical Contact Address
Technical Contact E Mail address
Technical Contact Phone number
Technical Contact Fax number

All other data elements containing contact information,
including new ones desired by other constituencies, could
be continued as voluntary elements; i.e., registrants
would have the right to fill them out or leave them blank as
desired.

We favor continued mandatory inclusion of the following data
elements:

Domain Status
Domain Name ID
Domain Name
Registrar ID*
Name of Registrar
Name Server(s)
Name Server ID*

Most of these are technical in nature. Note that we have
eliminated domain creation and expiration dates.
We believe that the inclusion of that information promotes
spamming and manipulative or fraudulent service offerings
from competing registrars. We can think of no legitimate purpose
that is served by requiring that information to be public; for
example, when one looks up someone's telephone number in a
white pages directory there is no statement about when the
line was rented. If that information is necessary for law
enforcement purposes it can be subpoenaed from registrar
records.

Our recommendations are intended to return Whois to its
original purpose as a technical coordination vehicle. We note
that the best way to improve accuracy of the data is to
provide privacy and security. Domain name registrants'
incentives to provide accurate information will dramatically
increase once they feel the information is secure.

If these data elements are not fully removed from the Whois
database, NCUC favors immediate adoption of privacy
protections for the WHOIS fields, and the creation of an
"opt-out" policy that allows a domain name registrant to fully
understand and freely choose whether or not to allow his/her
personal data to be published in worldwide directories and
available anonymously in any form. These options would apply
to all of the data elements we favor removing from the data
elements above.

===END OF PROPOSAL===
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