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---- >