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

[Alain Berranger]

Hi Wendy, Hi Konstantinos:

Thank you for this draft. I'm not sufficiently knowledgeable to have an
opinion and suspect a majority of NPOC members are in the same situation.

I'm flagging Lori, NPOC's interim Policy Committee Chair. I think that she
will decide how to contribute/respond or solicit NPOC members she knows
have a position to share or a comment to make.

In general and personally, I would say that if NPOC members stay silent or
do not have an argued position, then any NCSG policy that meets consensus
by active and knowledgeable NCSG members is obviously endorsed by both
constituencies.

What I would say is that more transparency is better (thick is better than
thin), subject to risk mitigation on fraud which I'm not competent to
comment, let alone make proposals. Also, if there is relevant work in
progress, then we should wait for the outcomes.

Alain

On Wed, Dec 28, 2011 at 6:19 AM, Konstantinos Komaitis <
k.komaitis at strath.ac.uk> wrote:

> Hi Wendy,
>
> this is a great statement - thanks for taking the time to draft this. I
> fully support it. I would hope that this would become an NCSG statement -
> can I ask whether NPOC would be willing to support it?
>
> Thanks
>
> KK
>
> PS: going back to eating now....
> ________________________________________
> From: NCSG-Discuss [NCSG-DISCUSS at LISTSERV.SYR.EDU] On Behalf Of Avri
> Doria [avri at ACM.ORG]
> Sent: Monday, December 26, 2011 2:24 PM
> To: NCSG-DISCUSS at LISTSERV.SYR.EDU
> Subject: Re: [NCSG-Discuss] [NCUC Public Comment] Thick and Thin Whois
> Preliminary issues report -- draft comment
>
> Hi Wendy,
>
> Thanks for taking time out of your holiday to do this.  I am quite happy
> with the statement.
>
> The only thing I would consider adding is another bit at the end of
> paragraph 3 on the process error made in the decision to require Thick
> Whois in the case of New gTLDs without a GNSO PDP effort.
>
> Something like:
>
> -
> If there is any consideration of a PDP on Thick Whois, it should include
> the issue of the legitimacy of the current Applicant Guidebook requirement
> on new gTLD applicants to use the Thick Whois model.   It is quite clear
> that this subject is within the scope of the GNSO, a scope that should not
> have been preempted by the New gTLD application process. The Issues report
> should cover this topic before any discussion on the appropriateness of
> extending the model to the incumbent registries.
> -
>
> I am in favor of this as a NCUC comment with or without the additional
> sentences.
>
>
> Thanks again,
>
> avri
>
>
>
> On 26 Dec 2011, at 02:51, Wendy Seltzer wrote:
>
> > I know the timing is tight, but here are some draft comments on the
> > Preliminary Issue Report on 'Thick' Whois
> > <http://www.icann.org/en/announcements/announcement-2-21nov11-en.htm>
> > (comment period closes Dec. 30)
> >
> > That preliminary report recommends that we start a PDP to make "thick"
> > WHOIS a consensus policy binding on incumbent registries (Verisign,
> > which has a thin WHOIS, with distributed registrar records, for .com and
> > .net). I think that's a bad idea.
> >
> > ----draft comment----
> > [] 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----
> >
> > Thanks to Avri for helpful suggestions starting the thread.  I propose
> > this as an NCSG or NCUC comment, depending on response.
> >
> > Thanks,
> > --Wendy
> >
>



--
Alain Berranger, B.Eng, MBA
Member, Board of Directors, CECI,
http://www.ceci.ca<http://www.ceci.ca/en/about-ceci/team/board-of-directors/>
Executive-in-residence, Schulich School of Business, www.schulich.yorku.ca
NA representative, Chasquinet Foundation, www.chasquinet.org
interim Membership Committee Chair, NPOC, NCSG, ICANN, http://npoc.org/
O:+1 514 484 7824; M:+1 514 704 7824
Skype: alain.berranger
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