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
[log in to unmask]
From: NCSG-NCUC
[mailto:[log in to unmask]] On
Behalf Of Rafik Dammak
Sent: Thursday, July 22, 2010 6:24
AM
To:
[log in to unmask]
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 <[log in to unmask]>
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 [[log in to unmask]]
On Behalf Of Debra Hughes [[log in to unmask]]
Sent: Wednesday, July 21, 2010
8:21 PM
To: [log in to unmask]
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