+1 Norbert = On 12/27/2011 09:49 PM, Milton L Mueller wrote: > 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---- >> -- A while ago, I started a new blog: ...thinking it over... after 21 years in Cambodia http://www.thinking21.org/ continuing to share reports and comments from Cambodia, and this is my last posting: Some clarifications – Christmas http://www.thinking21.org/?p=624 Norbert Klein [log in to unmask] Phnom Penh / Cambodia