[NCUC Public Comment] Thick and Thin Whois Preliminary issues report -- draft comment

[Milton L Mueller]

Wendy,
Great statement, I support it. I see  no reason why it couldn't be considered a NCSG comment as long as there are no objections forthcoming. 
And it was drafted by our SG's council rep who got the most votes!

--MM

> -----Original Message-----
> ----draft comment----
> [NCSG] offers this comment on the Preliminary Issue Report on 'Thick' Whois.
> 
> As an initial matter, we question the impetus for this policy-making.
> It is not clear that changing the thickness of WHOIS responds to the
> IRTP working groups' concerns about secure data exchange in a transfer,
> as neither the security properties nor alternatives are described in any
> detail.
> 
> The items in the Applicant Guidebook, in particular the requirement that
> all new gTLD applicants provide thick WHOIS, do not reflect a GNSO or
> community consensus.  It would therefore reverse the policy-making
> process to assert consistency with new gTLDs as a rationale for creating
> a policy that required existing registries to change their WHOIS model.
> The issue report correctly notes that no policy currently exists as to
> WHOIS model. We do not believe this PDP is the time or way to make such
> policy.
> 
> Further we question the timing and sequence of this proposed PDP.  A
> drafting team is currently developing a survey of WHOIS technical
> requirements, to gauge community needs from the WHOIS system.  Policy
> requiring thick WHOIS appears to offer a solution without before the
> problem is defined -- and so risks "solving" the wrong problem, while in
> the process reducing flexibility to solve actual problems that the
> community identifies.  We also have ongoing WHOIS studies. As the GNSO
> Council frequently hears about the overload on staff resources, and
> community members themselves face numerous competing demands on
> their
> time, we believe these resources could be better optimized by rejecting
> this PDP or postponing it until the prior WHOIS work gave definite
> objectives that required changes to the WHOIS model such as a thick WHOIS.
> 
> Within the report itself, we would like to see more consideration of
> alternative models, such as standards that could streamline the
> distributed database of thin WHOIS, or a centralized database.  Many of
> the format and accessibility concerns, for example, would appear to be
> better served by agreement on a standardized format for WHOIS data
> responses than by requirements on where the data must be kept. A new
> policy meant to address these concerns should look at their root causes,
> not
> 
> 
> As this preliminary issue report was completed before the adoption of
> the new PDP process, it does not contain the impact analysis recommended
> there. NCSG has particular interest in the impact on privacy rights.
> Moving all data to the registry could facilitate invasion of privacy and
> decrease the jurisdictional control registrants have through their
> choice of registrar.
> 
> ----end draft comment----
>