Comments filed today by American Red Cross

[Debra Hughes]

Thanks, Rafik.  The work of the JAS WG is very important and of course
related, in part, to the outreach work we are both involved with on the
OSC Constituency and Stakeholder Group Operations Work Team.

 

About the thin v. think comment below: In a thin registry (.COM is an
example), the Whois records includes limited data - only enough to
identify the registrar of the domain name (registrar name, registration
status, creation/expiration dates).  So, for a problematic .COM domain,
obtaining the contact details for the registrant is a two (or three or
four or five...) step process for research.  

 

For example,

Step 1: Look up the domain name using a Whois service of choice. Find
out registrar.

Step 2: Then, go to that particular registrar's Whois service to obtain
the publicly available Registrant's contact information. 

Step 3:  If the bad actor is using a privacy/proxy service, I have to
keep my fingers crossed that the privacy/proxy service has a fair (and
hopefully easy and inexpensive) system for me to request the concealed
contact information for the Registrant. Hopefully they will follow their
policy!

Step 4:  Proxy/privacy service does not have a system to request
underlying contact information or ignores request, I have to decide
whether it makes sense to spend donor dollars to get a subpoena, if
applicable or escalate the request for contact information.

 

A record from a registry operating a thick Whois server (like .ORG)
includes the registrant's contact information, admin/tech and the
registrar info.  It eliminates having to go two places to get the
publicly available Registrant contact info, which is important for not
for profit organization that are often asked to do more with less
resources.  The other benefit of a thick registry is when a registrar
goes out of business, the thick registry will retain the registrant info
(except if the registrant used a privacy/proxy service).

 

About the URS, I think fairness is important - fairness to the
registrant and a fair procedure for an organization that is being harmed
by a bad actor from a "clear cut" instance" of trademark abuse."  I
think the suggestion of giving Registrants 14 days, rather than 20 days
to file an Answer is fair, not abusive and consistent with the intent of
"rapid" suspension.  Also, if ICANN provides a form complaint and
reduces the word/page limit, it is possible a Registrant, who is
inexperienced with such actions, might feel less intimidated.  Also, the
suggestion of a form Answer can help inexperienced Registrants prepare
responses.

 

Debbie

 

Debra Y. Hughes l Senior Counsel 
American Red Cross 

Office of the General Counsel  
2025 E Street, NW 
Washington, D.C. 20006 
Phone: (202) 303-5356 
Fax: (202) 303-0143 
HughesDeb at usa.redcross.org <mailto:HughesDeb at usa.redcross.org>  

________________________________

From: NCSG-NCUC [mailto:NCSG-NCUC-DISCUSS at LISTSERV.SYR.EDU] On Behalf Of
Rafik Dammak
Sent: Thursday, July 22, 2010 6:24 AM
To: NCSG-NCUC-DISCUSS at LISTSERV.SYR.EDU
Subject: Re: Comments filed today by American Red Cross

 

Hello Debbie,

 

Thanks for comments sent to the JAS WG, the document is shared within
the WG members.

 

I was little bit puzzled by the mention of  supporting thick whois as
suggested by IRT, even there are some people arguing for that , I think
that a balanced solution for common ground of different interests is
mandatory with safeguard for privacy. also about URS, maybe we can
assume that there is need make it simple and short, how we can prevent
abuse of using URS for this supposed mechanism to prevent abuse?

Regards

 

Rafik

2010/7/22 Milton L Mueller <mueller at syr.edu>

Deb:

Glad to see that Red Cross is endorsing the idea that nonprofits might
use a new gTLD for "internal business purposes under a model that is
different from a commercial, profit-driven new gTLD"

 

________________________________

From: NCSG-NCUC [NCSG-NCUC-DISCUSS at LISTSERV.SYR.EDU] On Behalf Of Debra
Hughes [HughesDeb at USA.REDCROSS.ORG]
Sent: Wednesday, July 21, 2010 8:21 PM
To: NCSG-NCUC-DISCUSS at LISTSERV.SYR.EDU
Subject: [NCSG-NCUC-DISCUSS] Comments filed today by American Red Cross

All,

Attached are comments filed by the American Red Cross on the Joint SO/AC
Working Group Report and on DAG4.

<<American Red Cross Comments on Joint SO-AC WG Report - 07212010.pdf>>
<<American Red Cross Comments on DAGv4 - 07212010.pdf>> 

Thanks,

Debbie

Debra Y. Hughes l Senior Counsel

American Red Cross

Office of the General Counsel 

2025 E Street, NW 

Washington, D.C. 20006 

Phone: (202) 303-5356 

Fax: (202) 303-0143

HughesDeb at usa.redcross.org <mailto:HughesDeb at usa.redcross.org> 

 

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