Thick Whois WG Comments - with some proposed edits

[Kathy Kleiman]

    *Hi All,*

*Great thanks to Amr for the first draft of comments to the **Thick
Whois PDP Working Group. As you know, the question on the table is
whether a "thick Whois model" -- one in which all Whois data is held and
made available by the Registry (e.g., Verisign) and not the Registrar --
should be the model for all existing and all new gTLDs.*

    *For .COM, it's a huge issue. It is a "thin" registry, and 100
    million+ Whois records are stored by the registrar pursuant to local
    laws (including local privacy and free speech laws). Whether we can
    convert these 100 million+ records to a single database -- and
    whether we want to -- are questions for this group.*

    *Further, the issue of "Whois" data, service and protocol are all up
    in the air. If someday we reach agreement that this very personal
    data -- that can expose individuals and organizations to threat for
    what they say and share online (including political, religious and
    ethnic minority views and dissent, including non-commercial
    activity) -- should be private, then a single centralized Registry
    Whois database creates a single point of access. That means that
    should Registries be cozy with their local governments, all of this
    data may be relinquished without due process, or even subject to
    criminal laws that are non-standard in the world (e.g., Syria,
    N.Korea, China).*

    *The fact is that registrants know their registrars and it is to
    their registrars that the Whois information is provided. Most
    registrants will think they are protected under those rules. Despite
    the fact that New gTLDs (for this round, at least) require a
    centralized Whois -- with the Registry -- I remain deeply concerned
    about the consolidation of the massive .COM Whois (if it's even
    legal -- see below) and the standard set for all future registries
    and TLDs -- regardless of their political, social, or religious uses.*

*
If NPOC shares these concerns, I urge you to sign on -- with thanks!

Best, Kathy Kleiman (veteran of far too many Whois task forces and
review teams...)
p.s. Allof Amr's comments kept, and I added on and filled in some
sections... *
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